TMI Blog2023 (10) TMI 784X X X X Extracts X X X X X X X X Extracts X X X X ..... e builder for the acquisition of the subject property- containing cheque numbers, dates, amounts of each installment of loan released, bank details, interest charged (rate and amount); along with confirmation from the lender trust, copy of Income Tax return, balance sheet and details of the taxable income of trust. Assessee had taken a loan from Dayal Trust for the acquisition of the subject pr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... instant appeal, the appellant/revenue seeks to assail the order dated 08.12.2022 passed by the Income Tax Appellate Tribunal [in short, Tribunal ]. 3. The record shows that the Assessing Officer (AO), via the assessment order dated 22.12.2018, had made additions on account of an unsecured loan obtained by the respondent/assessee from a trust going by the name Dayal Trust. The addition on accou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... CIT(A) s order by the appellant/revenue, the Tribunal dismissed the appeal and sustained the said order. 7. The record discloses that one of the errors that the AO had committed was his failure to notice that the interest paid by the respondent/assessee to Dayal Trust was bifurcated amongst the beneficiaries of the trust, which was thereafter taxed in their hands. 7.1 This aspect has been du ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... .2020 in paragraph 10 of the impugned order. 11. According to us, the addition made by the AO was not called for in the instant case. The respondent/assessee had been able to place the relevant material to back his explanation that the entry in its books of accounts was nothing but a loan extended by Dayal Trust. 12. Thus, for the foregoing reasons, we are of the view that no substantial que ..... X X X X Extracts X X X X X X X X Extracts X X X X
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