Taxpayer Wins ₹4.04 Cr Relief: AO Cannot Rely on Non-Response to S.133(6) Notice – Reason: Onus Shifts to Revenue After Primary Proof

DCIT Vs Eskag Sanjeevani Pvt. Ltd. (ITAT Kolkata)

Unsecured loans not bogus – ITAT Kolkata upholds deletion of ₹ 4.04 Cr u/s 68 & interest addition- Full documentation saves ₹ 4 Cr loan – Repayment through banking channels proves genuineness – Shell-company theory rejected – Burden shifts to AO after assessee’s proof – Reopening based on old statement struck down

Revenue filed appeals against CIT(A)’s order dated 28.05.2024 deleting an addition of ₹ 4,04,50,000 made u/s 68 towards unsecured loans taken from Asha Apartments Pvt Ltd

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