Section 68 addition remanded — Identity proved shifts onus to AO; Failure to invoke Section 133(6) grant opportunity held improper

Afzal Pasha Vs DCIT (ITAT Bangalore)

ITAT condoned delay of 130 days considering medical condition & held that genuine health issues constitute sufficient cause; appeal admitted on merits.

AO treated unsecured loans of ₹2.28 Cr as unexplained u/s 68 merely because lenders were from unorganised sector & did not file ITR/GST; CIT(A) confirmed addition without deeper verification. Assessee had furnished PAN & Aadhaar of lenders & loans were recorded in audited books

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