Unsecured loans through banking channels cannot be treated as unexplained credits absent transaction specific incriminating material.
Unsecured bank routed loans cannot be treated as unexplained credits where the assessee produced confirmations, lender bank statements, audited accounts and tax filings, and the Assessing Officer relied chiefly on uncorroborated third party search statements or administrative press releases without transaction specific incriminating material. For years prior to the Finance Act, 2022 amendment, a generalized source of source obligation for loan credits is not mandated; repayments in the lender's account are distinct from fresh upstream borrowings. Appellate authorities may independently verify facts under their powers if the AO is given opportunity to respond.