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2019 (5) TMI 1115 - AT - Income TaxRevision u/s 263 - unsecured loan transactions - Lack of enquiry V/S inadequate enquiry - as per Pr. CIT, AO failed to make proper enquiry with respect to unsecured loans reflected in the books of assessee - Pr. CIT in the impugned order has pointed specific instances where the lenders have common addresses raising an eye of suspicion and also creditworthiness of lenders has not been verified by the AO - HELD THAT:- As per the list furnished by assessee there are 23 lenders of unsecured loan. As is evident from documents furnished before us, the remaining 21 parties have not responded to the notice issued by Assessing Officer. Though the assessee has furnished various documents i.e. confirmations of the parties, return of income filed by the lenders, their ledger extracts etc., but their non-appearance before the Assessing Officer raises an eye of suspicion, especially when majority of lenders are stated to be closely related to the assessee. In majority of cases loans have been advanced by the parties after similar amounts have been credited to their respective bank accounts. This finding has not been controverted by assessee. AO after having received relevant documents including confirmation has not taken pains to verify the veracity of loan transactions and the creditworthiness of the parties extending loan. AO after issuing notices u/s. 133(6), left the enquiry in between. Therefore, it is case of lack of enquiry by Assessing Officer and not inadequate enquiry as has been asserted by the assessee. - Decided against assessee.
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