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Merely filing Nil return by lender, if the sources are clearly established with overwhelming evidences of the bank statements of all the concerned parties duly supported by the annual accounts, cannot lead to addition in the hands of the borrower.

Sec. 68 of Income Tax Act, 1961—Cash Credit— NBFC companies who have limited earning but lent the money out of the money borrowed will never pass the test of section 68, thus, merely filing Nil return by lender, if the sources are clearly established with overwhelming evidences of the bank statements of all the concerned parties duly supported by the annual accounts, cannot lead to addition in the hands of the borrower under section 68 - SUPREME BUILD-CAP PVT. LTD. V/s ASSTT. CIT - [2020] 27 ITCD Online 027 (ITAT-DELHI)