TaxTMI 
TaxTMI 
2026 (5) TMI 396
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....ing to A.Y. 2014-15 arising out the assessment order dated, 30-12-2016 u/s 143(3) of the Income-tax Act, 1961, (in short 'the Act'). 2. The assessee has raised the following grounds in appeal as under: 1. Order passed by the Learned Commissioner of Income Tax (Appeals) (hereinafter referred to as "Ld. CIT(A)) for the AY 2014-15 is bad in law and on the facts. 2. That on the facts and circumstances of the case the Ld. CIT(A) has erred in sustaining addition of Rs. 58,00,000/- u/s 68 of the Income-Tax Act, 1961 despite providing all the necessary details of lenders i.e. Proof of identity, PAN acknowledgement of filing income tax returns, Jurisdiction, loan/balance confirmations affidavit and bank statement and totally ign....
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....essee. 5. Being aggrieved the order of the Ld. CIT(A) the assessee is in appeal before the Tribunal. 6 Ld. AR of the assessee submitted that the assessee had discharged initial burden by providing identity of all creditors by giving their complete addresses, Permanent account number, confirmation of loan, photo copy of the Bank account statement, confirmation of repayment and copy of the acknowledgement of the ITR. He further submitted that the loan was received through banking channel and repayment also made through payee cheques. The assessee has established the genuineness of the transaction. Reliance is placed on the following decisions: (i) Deputy Commissioner of Income -Tax v. Rohini Builders [2003]127 taxman 523 (Gujar....
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.... we see no reason to interfere with the impugned order passed by the ITAT. No question of law, much less substantial question of law arises in the present Tax Appeal. Hence, the present Tax Appeal deserves to be dismissed and is accordingly dismissed. 7. The Ld. Sr. DR relied upon the order of the lower authorities. We have heard both the parties and perused the material available on record. Ld. CIT(A) has observed in his order as under: "8. Conclusion 8.1 After careful consideration of the assessment order the grounds raised in appeal, the submission and documents furnished by the appellant and the legal arguments advanced it is evident that the appellant has failed to discharge the primary onus cast upon her under sec....
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....mounting Rs. 81,00,000. To prove the creditworthiness a of the lenders and the genuineness of the loans the assessee has filed the affidavits of the lenders, copy of the PAN, copy of the banks accounts, copy of the acknowledgements of the ITR, confirmation letter of the loans and the documents related to the repayments by which the loans were repaid. The assessee has discharged her burden by giving the details of the parties. The documents filed by the assessee cannot be doubted on the basis of the uniformity. The, AO has not brought any adverse material on record to establish that the confirmation letters filed by the assessee were not genuine. It is also observed that the AO inference that the two lenders namely Sh. Surender Kumar Jain an....