Reassessment based on specific investigation information upheld where alleged accommodation-entry loan showed a live nexus with escaped income.
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....Specific investigation information linking an unsecured loan to an alleged accommodation-entry lender can establish a live nexus for reassessment; conclusive proof of escaped income is not required when reasons are recorded. Reassessment was upheld on that basis. Confirmation and banking records alone do not establish an unsecured loan's creditworthiness or genuineness where the lender does not respond to statutory notice, is not produced for examination, and adverse investigation material remains unrebutted. The loan was treated as unexplained cash credit and related interest was disallowed. Business-loss set-off and carry-forward require sufficient material demonstrating compliance with statutory conditions; unsupported current-year and brought-forward loss claims were rejected.....
TaxTMI