MAHAVIR RAMNARAYAN BHATTAD,CHANDRAPUR vs. DCIT/ACIT CIRCLE-AMRAWATI, AMRAVATI

ITA 682/NAG/2025Status: DisposedITAT Nagpur31 August 2026AY 2018-196 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessee had discharged the burden under Section 68 by providing primary evidence like ledger accounts, confirmations, ITRs, and bank statements. Furthermore, the Tribunal noted that the requirement to explain the 'source of source' was introduced later and not applicable to the assessment year in question, and that the loans had been repaid.

What were the facts?

The assessee received unsecured loans totaling Rs. 2,45,47,460 and claimed interest expenses of Rs. 19,96,080. The Assessing Officer added the loan amount and interest expense to the assessee's income, holding that the assessee failed to establish the creditworthiness of the lenders.

What were the issues?

Whether the assessee discharged the onus under Section 68 by providing sufficient evidence of unsecured loans, and whether the 'source of source' explanation was required for the assessment year.

Which sections of the Income-tax Act were involved?

Section 68

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “DB” BENCH, NAGPUR

Before: SHRI ANUBHAV SHARMA & SHRI KHETTRA MOHAN ROY

Hearing: 11.06.2026Pronounced: 31.08.2026

PER ANUBHAV SHARMA, JM:

This appeal is preferred by the assessee against the order dated 09.10.2025 of the Ld. National Faceless Appeal Centre (NFAC) Delhi (hereinafter referred as Ld. First Appellate Authority or in short Ld. ‘The FAA’) in DIN & Order No: ITBA/NFAC/S/250/2025-26/1081586119(1) arising out of P a g e | 2 Mahavir Ramnarayan Bhattad (AY: 2018-19) the assessment order dated 18.03.2021 u/s 143(3) read with section 143(3A) & 143(3B) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) passed by National e-Assessment Centre, Delhi, for AY: 2018-19. 2. Heard and perused the records

The order continues below.

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