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ITAT Nagpur Deletes Sec 69A Addition – Small Loans from Friends & Relatives Explained with Identity & Banking Evidence

Case Law Details

TaxGuru Citation
2026 taxguru.in 2436
Case Name
Pawan Pandurang Nimkar Vs ITO (ITAT Nagpur)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2022-2023
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Pawan Pandurang Nimkar Vs ITO (ITAT Nagpur)

Small Loans from Friends Relatives Explained – Addition U/s 69A Deleted on Filing Identity Proofs Banking Evidence – ITAT Nagpu

The AO made addition of ₹1.23 lakh u/s 69A treating multiple small bank credits as unexplained money. Assessee contended that amounts were small loans received through banking channels from friends & relatives and furnished lender details, declarations & identity proofs.

ITAT observed that there were 42 small transactions ranging from ₹1,000 to ₹39,528 supported by bank statements and documentary evidence, and overall bank balance was modest. Considering that the nature & source of credits stood explained and lenders’ identity was established, the Tribunal held that addition u/s 69A was unjustified. Accordingly, the addition was deleted and appeal allowed

FULL TEXT OF THE ORDER OF ITAT NAGPUR

This appeal at the instance of the assessee is directed against the order of Ld. Commissioner of Income Tax (Appeals)/NFAC, Delhi [“CIT(A)”], dated 12/08/2025 passed u/s. 250 of the Income Tax Act, 1961 (for short, ‘the Act’) which is arising out of assessment order dated 19.03.2024 passed u/s. 143(3) r.w.s. 144B of the Act for the Assessment Year 2022-23 (A.Y.)

2. The sole grievance of the assessee is against the finding of the Ld.CIT(A) confirming the action of the Ld.AO making addition of ₹ 1,23,382/- u/s. 69A of the Act.

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Author Info

CA Vijayakumar Shetty
Qualification: CA in Practice
Company: Shetty & Co, Chartered Accountants, Mangalore
Location: Mangalore, Karnataka
Articles Published: 6,164

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