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TMI Blog2022 (6) TMI 1481X X X X Extracts X X X X X X X X Extracts X X X X ..... hannels by account payee cheques and the said transaction is also duly reflected and disclosed in the books of accounts of the lender company. This proves the genuineness of the transaction of the loan. We find that the lender company is duly assessed to income tax which is evident from the income tax return acknowledgement enclosed before the lower authorities. This clearly proves the identity of the lender. The assessee had also filed confirmation from the lender confirming the loan transactions. All the aforesaid facts were also duly confirmed by the lender directly before the ld. AO in response to notice issued u/s.133(6) by the ld. AO. We also find from the ledger account of the lender enclosed in the paper book that the loan has been ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the ground No.1 is hereby dismissed as not pressed. 3. The other grounds raised by the assessee are merely challenging the confirmation of addition by the ld. CIT(A) towards unexplained cash credit u/s.68 of the Act in the sum of Rs.10,00,000/- in respect of loan received by the assessee and disallowance of interest paid on such loan. 3.1. We have heard rival submissions and perused the materials available on record. We find that assessee borrowed a sum of Rs.50,00,000/- from a concern M/s. Confidence Finance Trading Ltd., during the year under consideration. The assessee paid interest of Rs.1,96,315/- on this loan and claimed the same as deduction. The nature and source of loan received by the assessee from the said party was sought to be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... entire transactions with the assessee. The assessee also filed confirmation of loan balances from the lender before the ld. AO. The assessee pleaded that all these evidences collectively proved all the three necessary ingredients of Section 68 of the Act. However, the ld. AO did not heed to the contentions of the assessee and proceeded to make an addition u/s.68 of the Act and consequentially disallowed the interest paid thereon. This action of the ld. AO was upheld by the ld. CIT(A). 3.2. We find that all the documents that are relevant for the purpose of proving the genuineness of the loans had been duly furnished by the assessee as detailed above. We find that assessee had also enclosed the bank statements of the lender company which pro ..... X X X X Extracts X X X X X X X X Extracts X X X X
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