2026 (3) TMI 554

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...., Jalgaon for the Assessment Year (AY) 2016-17. 2. The sole grievance of the assessee is that Ld.CIT(A) erred in confirming the addition made by the Ld. Assessing Officer (AO) u/s. 68 of the Act for the unexplained unsecured loans amounting to Rs. 23,60,000/- 3. At the outset, learned counsel for the assessee submitted that the alleged unsecured loans taken from 07 persons who are female family members of Promoters, Directors and Shareholders of the assessee company and they have given loans out of their accumulated savings. He also submitted that the alleged cash creditors have provided Permanent Account Numbers (PANs) and confirmation of account. He, therefore, prayed that the impugned addition may please be deleted. 4. Ld. Addl.....

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....unsecured loans. Ld.AO, thus, concluded the proceedings making addition of Rs. 23,60,000/- invoking section 68 of the Act treating them as unexplained cash credits and income assessed at Rs. 90,80,280/-. Subsequently, assessee preferred appeal before the Ld.CIT(A), but could not succeed because assessee failed to controvert the observation of the Ld.AO that prior to issuance of cheques to the assessee company, there has been a cash deposit in the bank account of the respective cash creditors. Now assessee is in appeal before this Tribunal. 7. We have gone through the details filed by the assessee in the paper book running into 92 pages. Section 68 of the Act has been invoked alleging that assessee has failed to explain the nature and sou....

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....ny, there is a cash deposit in the bank account of each of the alleged cash creditor. It is also observed that each of the cash creditors are not having regular source of income because the copy of income tax returns of each of such cash creditors are not filed. Admittedly, all the cash creditors are having PAN and transactions are carried out through banking channel. So far as cash deposits in the bank account prior to issuance of cheques to the assessee company is concerned, we note that the basic income tax exemption limit for A.Y. 2016-17 is Rs. 2,50,000/- and therefore, if the income of any individual does not exceed Rs. 2,50,000/- for A.Y. 2016-17, then there is no tax liability on such individual. For the senior citizen, the limit is....