Requirement to explain ‘source of source’ was restricted to Share Capital and couldn’t be extended to unsecured Loans

ITO Vs Vastimal Bhim Raj Sancheti (ITAT Bangalore)

Conclusion: Assessee had satisfactorily explained the source of credits in his books and consequently, CIT(A) had rightly deleted the additions after relying on various judgments made by AO. The obligation to explain the “source of source” under Section 68 was restricted to credits like share capital and did not extend to unsecured loans received.

Held: Assessee, had received unsecured loans amounting to Rs. 5.87 crore and Rs. 8.31 crore from Magnificent Realcon Pvt. Ltd. (MRPL) during t

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