BKSONS INFRASTRUCTURE PRIVATE LIMITED,GUWAHATI vs. ACIT, CENTRAL CIRCLE-1, GUWAHATI, GUWAHATI

ITA 123/GTY/2026Status: DisposedITAT Guwahati27 August 2026AY 2021-225 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal noted that no agreement for the loan was produced and the assessee was not given an opportunity for cross-examination. Therefore, the issue was remitted back to the AO for fresh consideration.

What were the facts?

The assessee took an unsecured loan of Rs. 1,50,00,000/- which was treated as an accommodation entry by the Assessing Officer (AO). The AO made an addition under Section 68 of the Income Tax Act, 1961, which was confirmed by the CIT(A).

What were the issues?

Whether the unsecured loan was a genuine transaction or an accommodation entry, and whether the assessee was denied a proper opportunity for cross-examination.

Which sections of the Income-tax Act were involved?

Section 68,Section 132,Section 143(2),Section 139,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “DB” BENCH, GUWAHATI

For Appellant: Shri S.P. Bhati, AR
For Respondent: Shri Santosh Kumar Karnani, DR
Hearing: 08.07.2026Pronounced: 27.08.2026

PER LAXMI PRASAD SAHU, ACCOUNTANT MEMBER

This appeal is filed by the assessee against the orders passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by the CIT(A), Central NER, Guwahati [hereinafter referred to as “the Ld. CIT(A)] dated 27.01.2026, DIN & order No. ITBA/APL/S/250/2025- 26/1085023139(1). The assessee has raised following grounds of appeal:

2 BKSons Infrastructure Private Limited; A.Y. 2021-22 “1. For that under the facts & circumstances of the case the learned A.O. is not justified in making addition of Rs.1,50,00,000/-u/s 68 of I.T. Act, 1961 and CIT(A)

The order continues below.

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