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2023 (6) TMI 875 - ITAT AMRITSARUnexplained cash credits - onus to prove creditworthiness of creditors - HELD THAT:- Since, the identity of loan creditor stands established as he attended proceedings before the AO and the appeal proceedings as well and the genuineness of transaction is established as the loan was given through banking channel and that credit worthiness to pay advance to the appellant is established as discussed above and hence the addition has been rightly deleted by the Ld. CIT(A). Disallowance of interest paid to the two loan creditors on account of unexplained credits - HELD THAT:- It is evident from the record that the appellant was paying interest to the loan creditors @ 12% PA on the borrowings and since the interest amount was paid to them after deducting TDS, therefore the addition on account of interest paid/payable to the said creditors is also required to be deleted. Since, the interest expenses paid to the loan creditors are subject to TDS and hence, interest paid/payable to the said creditors is genuine and stands explained accordingly. CIT(A) was justified in deleting the addition on account of interest paid by the assessee to the loan creditors. Decided against revenue.
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