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Assessee Not Required to Prove Source of Source for Alleged Accommodation Loan: ITAT Mumbai
Case Law Details
- TaxGuru Citation
- 2026 taxguru.in 2583
- Case Name
- ACIT Vs Trishul Reality Infra LLP (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2012-13
- Courts
- All ITAT, ITAT Mumbai
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ACIT Vs Trishul Reality Infra LLP (ITAT Mumbai)
Addition u/s 68 on Alleged Accommodation Loan Deleted – Assessee Not Required to Prove Source of Source for Unsecured Loan – ITAT Mumbai
The Revenue challenged deletion of addition of ₹40 lakh u/s 68 alleging that the assessee LLP was ultimate beneficiary of accommodation entries routed through a shell company, M/s Mahagouri Vintrade Pvt. Ltd., via lender M/s Gulmohar Towers Pvt. Ltd. The AO treated the loan as unexplained on the basis of Investigation Wing findings that the upstream company was a paper entity.
ITAT noted t...
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