TaxTMI 
TaxTMI 
2025 (2) TMI 2002
X X X X Extracts X X X X
X X X X Extracts X X X X
....d the following grounds of appeal: 1. The order of the CIT(A) relating to upholding the addition of Rs. 24,20,000/- u/s. 69A of the Act is erroneous as the same is contrary to the facts of the case and provisions of law. 2. The CIT(A) erred in failing to delete the addition of Rs. 24,20,000/- as the same has been made without considering the submissions and documents filed by the appellant. 3. The appellant having furnished the explanation and proved the source and genuineness of the loan received, the CIT(A) grossly erred in upholding the addition made by the AO. 4. The addition being unsustainable u/s. 69A of the Act, the CIT(A) ought to have deleted the same. 5. The loan borrowed having been a....
X X X X Extracts X X X X
X X X X Extracts X X X X
....had furnished proof for receipt of the loan before the AO and hence, stated that there is no logic or reason to such loan as addition u/s. 69A of the Act, and hence, prayed for deleting the additions. However, the CIT(A) was not convinced with the explanation provided by the assessee and confirmed addition of Rs. 24,40,000/- by holding as under:- "5.2.3 : The appellant submitted that he obtained personal loan Rs. 24,20,000/- from his friend Mr Sevugon. Mr Sevugon is the proprietor of M/s. Excellent Products of India and the fund has been transferred from the proprietary entity to the account of the appellant. The appellant failed to produce even the ledger extract in the books of M/s Excellent Products of India before the AO. ....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... assessee assailed action of the CIT(A) stating that both the lower authorities have erred in making addition of Rs. 24,20,000/- u/s.69A of the Act, even though the assessee has filed entire details of loan received along with bank statement, PAN of lender and also confirmation letter from lender. 6. Before us, the Ld.AR submitted a paper book consisting of 69 pages having details of notices issued by the AO, bank statement of the assessee for financial year 2020-21 in respect of Indian Overseas Bank two accounts and Federal bank, submissions made by the assessee before the AO, written submissions filed by the assessee before the CIT(A), GST return of Mr. Sevugon as well as invoices raised by M/s. Excellent Products of India and certain ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....claring his salary income. During the course of assessment proceedings, the assessee was asked to furnish details of credits to the tune of Rs. 34,50,000/- by the AO. The assessee explained that said sum was received from his friend Mr. Sevugon, proprietor of M/s. Excellent Products of India to the tune of Rs. 24,20,000/- Rs. 9,50,000/- has been transferred from his bank account held at Federal Bank and Rs. 80,000/- was cash deposited. Further, it is noted that the assessee had filed confirmation letter to the tune of Rs. 24,20,000/- from Mr. Sevugon quoting his PAN along with bank transfer details. However, the AO has made addition u/s. 69A of the Act as unexplained money to the tune of Rs. 24,20,000/- in the assessment order. The CIT(A) a....