Section 68 Addition Deleted: ITAT Rejects Addition Based Solely on Retracted Survey Statement

DCIT Vs Privi Exports Private Limited (ITAT Kolkata)

ITAT Kolkata Upholds Deletion of ₹10.25 Crore u/s 68 — Loans Found Genuine & Supported by Evidence

Kolkata ITAT dismissed the Revenue’s appeal against Privi Exports Pvt. Ltd., confirming the CIT(A)’s deletion of addition u/s 68 on unsecured loans of ₹10.25 crore.

Facts

AO, after a survey u/s 133A, noted that the company allegedly brought back its unaccounted money in the guise of unsecured loans based on statements of its directors Shri Vishwanath Gupta & Shri Vivek G

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