2026 (4) TMI 1472

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....ers of the ld. Assessing Officer (hereinafter referred to as the Ld. AO, for short) passed u/s 147 r.w.s. 143(3) of the Income-tax Act, 1961 (hereafter referred to as 'the Act'). Further details of the orders of the lower authorities are as under:- ITA No. & AY Ld. FAA who passed the appellate order Appeal No. & Date of order of the Ld. FAA AO who passed the assessment order & Date of order 5955/D/25 2020-21 CIT(A)-3, Noida DIN & Order : ITBA/APL/M/250/2025-26/1078546942(1) Dated 16.07.2025 DCIT, Central Circle-1, Noida Dated 30.03.2024 5956/D/25 2022-23 CIT(A)-3, Noida DIN & Order : ITBA/APL/M/250/2025-26/1078674540(1) Dated 18.07.2025 DCIT, Central Circle-1, Noida Dated 30.03.2024 2. The appeal....

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....and we find that to establish the identity, genuineness and creditworthiness of the parties and the transaction, all the primary documents were furnished before the Learned Tax Authorities below. The assessee had demonstrated that in the audited balance sheet for AY 2020-21, this company had reflected shareholders' funds of Rs. 64 crores and above, and investments amounting to Rs. 124 crores and above. Assessee had substantial investments in listed entities like Vipul Limited of Rs. 2.37 crores and in quoted debentures of Vodafone Idea Limited of Rs. 95.30 crores. It also brought on the record that M/s Teesta Retails Pvt. Ltd., which is part of the Reliance Group had invested Rs. 400 crores in this company in the form of Compulsory Converti....

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....was no burden on assessee to prove the "source of source", the evidence filed and the background of the investor did not warrant doubting the transaction and Ld. CIT(A) had duly benefited the assessee. The corresponding ground, with regard to, additions of unsecured loan or the interest on unsecured loan, have no substance. 9. Addition of Rs. 1 crore was made in AY 2020-21, on account of unsecured loan received from M/s Sundrm Consultants Pvt. Ltd. and we find that Ld. CIT(A) had appreciated the fact that, the assessee had not received any loan or credit in FY 2019-20, and there was merely a journal entry reflecting the transfer of credit balance from previous transactions. It is also appreciable, Assessing Officer had not objected to th....