Third-Party Statement Alone Insufficient to Treat Loan as Bogus

DCIT Vs Metallica Metals India (ITAT Mumbai) 153C Additions Can’t Rest on Third-Party Statements Alone: ITAT Mumbai Upholds Deletion of Unsecured Loan & Notional Interest ITAT Mumbai (D Bench) in DCIT-CC-8(4) vs Metallica Metals India (ITA Nos. 4289 & 4290/Mum/2025; AYs 2019-20 & 2020-21; order dated 23.12.2025) has dismissed the Revenue’s appeals, affirming the deletion of additions u/s 68 and consequential commission/notional-interest additions made in search-related assessments u/s 153C. Pursuant to a search u/s 132 in a third-party case, the AO treated an unsecured loan...