Section 68: Explaining Source of Source Funds for Unsecured Loans Not Required Pre-01.04.2023

Sheela Overseas Private Limited Vs PCIT (Delhi High Court) Delhi High Court held that that Section 68 of the Act as was in force prior to 01.04.2023, did not require the assessee to explain the source of the source of funds in case of unsecured loans. Accordingly, addition is liable to be deleted and appeal allowed. Facts- The Assessee is engaged in the business of readymade garments and leather goods. During the year, the Assessee had received unsecured loans aggregating to ₹83,00,000/- from its two directors namely, Mr. R.C. Bhatia and Mr. Hitesh Bhatia. AO treated the sum of ₹51,00,000/...