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2022 (9) TMI 375 - AT - Income TaxAddition u/s 68 - addition of unsecured loans - assessee failed to verify the genuineness and creditworthiness of the lenders - Case selected for scrutiny and notice us 143(2) and 142(1) issued - CIT-A deleted the addition - HELD THAT:- The assessee has received the unsecured loans from 9 parties who are having the opening balance of unsecured loans with the assessee in the F.Y.2011-12. AR demonstrated the confirmations - We are of the view that the CIT(A) has considered the submissions and evidences and granted the relief. Further the provisions of section 68 of the Act cannot be invoked on the opening balance of unsecured loan. The Ld.AR has demonstrated the Assessment order passed U/sec 143(3) for A.Y.2011-12 of the assessee , where the return of income was accepted. Unsecured loan disclosed in the Balance sheet received by the assessee in the earlier years in full and final settlement with the partnership firm - AR has demonstrated the submissions made before the A.O by letter filed on 27-03-2015 explaining the facts and circumstances of receipt of money in the financial year 2007-08. AR has highlighted the transactions with the details of payments made to the assessee and supporting bank statements of M/s Time Star Ltd which cannot be over looked - DR could not controvert the findings of the CIT(A) with any new evidence or information to take a different view. We find that the CIT(A) relied on the judicial decisions and also the facts, additional evidence, remand report and provisions of Sec. 68 of the Act has passed a reasoned order. Accordingly, we are not inclined to interfere with the order of the CIT(A) and upheld the same and dismiss the grounds of appeal of the revenue
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