ITAT Pune: ₹1.62 Cr u/s 68 Deleted — No “Source of Source” Needed Pre-01.04.2023

Dhaval Vinod Gada Vs DCIT (ITAT Pune) ITAT Pune Deletes ₹1.62 Cr u/s 68 — “Source of Source” Not Required for Unsecured Loans Before 01.04.2023 The ITAT Pune deleted the addition of ₹1.62 crore u/s 68, holding that the assessee had fully proved the identity, creditworthiness and genuineness of the loan received from Shri Manilal M. Gada, who responded with confirmations and bank statements. Although the AO treated the loan chain—from lender to his wife to land vendors—as an accommodation arrangement, the Tribunal noted that the assessee had explained even the source of the source...