2026 (2) TMI 707

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....the CIT(A) was incorrect and unjustified: i) In confirming the disallowance of Rs 16,66,640/- on account of expenses u/s 37. ii) In confirming the addition of Rs 16,66,640/- on account of bogus purchases whereas the assessing officer had disallowed the amount u/s 37. iii) In confirming the addition of Rs 92,72,000/- incorrectly and unjustifiably made by the assessing officer u/s 68 of the IT Act in the account of Shiv Shakti Realtors Pvt Ltd and the CIT(A) also further erred in confirming such addition without finding the confirmations incorrect. iv) In confirming the addition of Rs 20,00,000/- in the account of Naveen Agarwal/Archita incorrectly and unjustifiably made by the assessing officer u/s 68. ....

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....etails. Aggrieved, the assessee went in appeal before the ld. CIT(A) who disallowed the same u/s 37 of the Act. 6. Now the assessee is in appeal before us. 7. Before us, the ld. counsel for the assessee vehemently stated that the company had purchased construction material for which material purchase details were submitted before the Assessing Officer as well as before the CIT(A), including vendor names, addresses, voucher numbers, dates, and amounting to Rs. 20,07,400/-. The Assessing Officer did not raise any further queries nor conducted any verification with the creditors, which clearly establishes the acceptability of the expenses incurred. The said expenses are wholly and exclusively incurred for the purpose of business and are ....

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....ent in appeal before the ld. CIT(A) who confirmed the addition of Rs 1,62,72,000/- out of Rs. 1,69,72,000/-. 12. Aggrieved, the assessee is in appeal before us. 13. Before us, the ld. counsel for the assessee vehemently stated that the Assessing Officer observed that the assessee had taken unsecured loans from 5 parties for which various documentary evidences were submitted establishing the three parameters under section 68 of the Act i.e. the identity and creditworthiness of the lenders and genuineness of the loan transactions. Further the said parties have confirmed the loan transaction by filing replies u/s 133(6) of the Act and this fact has been duly accepted by the Assessing Officer in the assessment order. Furthermore, the loan....