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Whether on the facts and circumstances of thecaseand in law, the Hon'ble ITAT erred in upholding the order passed by the Ld. CIT(A) without considering the effect of the provisions of Section 292C of the I.T. Act?

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Sec. 143 & 292C of Income Tax Act, 1961—Income From Undisclosed sources - The impounded sheet contained name of probable lenders as date of interest column dated and amount of interest payable has been found as blank. Further, six persons mentioned in the chart have denied to have done any financial transactions with the assessee. The AO wrongly treated these as loans given. Thus, the impounded sheet contained name of probable lenders as date of interest column dated and amount of interest payable has been found as blank. Further, six persons mentioned in the chart have denied to have done any financial transactions with the assessee. The AO wrongly treated these as loans given whereas the list/chart indicates probable lenders. The AO did not bring on record anything contrary to the submissions made by the assessee. Thus, Tribunal justified in upholding the order passed by the CIT(A) in respect of addition made on account of unaccounted loan and advances and interest of Rs. 4,82,56,000/¬ by accepting the explanation of the assessee. Appeal of the revenue dismissed. - CIT V/s GHANSHYAM DUNGARBHAI SUTARIA - [2020] 425 ITR 601 (GUJ)

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