Opening Balance Cannot Be Taxed u/s 68: ITAT Remands ₹55.53L Loan Addition for Verification

Sree Tirumala Spices Vs ITO (ITAT Hyderabad) The Hyderabad ITAT held that Section 68 cannot be invoked on opening balances, but remanded the matter for factual verification. The case involved addition of ₹55.53 lakh treated as unexplained cash credit, representing an outstanding loan from a creditor. The assessee contended that the amount was not a fresh credit during the year, but merely a carried-forward opening balance, reduced from ₹92.53 lakh after partial repayment. However, the AO and CIT(A) made the addition citing lack of proof of creditworthiness and genuineness. The Tribunal obs...