2025 (4) TMI 1845

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....h, A.R. For the Respondent : Shri Kavan Limbasiya, Sr. D.R. ORDER PER SIDDHARTHA NAUTIYAL - JUDICIAL MEMBER: This Miscellaneous Application has been filed by the assessee against the order dated 16.01.2025 upholding addition of Rs. 1,77,24,909/- under Section 68 of the Act in respect of loans taken by the assessee from seven parties. 2. The brief facts of the case are that the asses....

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....th the amounts advances to the assessee. It was noted that in most of these cases, the bank accounts had minimal balances and there were no transactions in the bank account of the lenders and once the amount had been credited in the bank accounts of the lenders, the same were transferred to the assessee within a short gap of time. All these facts were specifically noted at Pages 6 to 9 and Pages 1....

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....ere liable to be sustained in the hands of the assessee. 3. The assessee has filed the present Miscellaneous Application stating that the ITAT has omitted to consider certain evidences in support of the creditworthiness of these seven parties. 4. On going through the Miscellaneous Application filed by the assessee and written submission filed by the assessee, in our considered view, vide the....

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....e considered view that with respect to these seven parties, the assessee could not establish their genuineness or creditworthiness. It was specifically noted that common trend among the seven lenders were that they were either filing no return of income or were filing a low return of income not commensurate with the advances given to the assessee, these lenders were maintaining minimal balances in....