2026 (4) TMI 643

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....esh Goenka, Advocate. ORDER PER: BENCH This is an appeal preferred by the revenue against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the "Ld. CIT(A)"] dated 15/07/2024 for the AY 2017-18. 2. The only issue raised by the revenue in the various grounds of appeal is against deletion of addition of Rs. 8,25,00,000/- by the ld. CIT(A) by admitting ne....

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....s the assessee stated that interest rate was 12%. The Assessing Officer finally treated the impugned loans by three loan creditors aggregating to Rs. 8,25,00,000/- as unexplained cash credit as the necessary ingredients of Section 68 of the Act were not specified and added to the income of the assessee. 4. In the appellate proceedings, the ld. CIT(A) allowed the appeal of the assessee after giv....

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.... creditors before the Assessing Officer as well as the ld. CIT(A) and the ld. CIT(A) deleted the same after taking into account these evidences. Similarly in respect of Shri Mohit Sethia and Smt. Sarala Sethia from whom unsecured loans of Rs. 4,60,00,000/- and Rs. 3,45,00,000/- were taken during the year, there were also part repayment during the year. We note that the assessee had paid interest o....