much as these loans have been
received from the existing loan creditors only, who had already advanced loans to the
assessee in the earlier year ... interest on unsecured
loans to all the 8 parties upto the date of conversion of the loan amounts into equity.
These unsecured loans were converted
stated by the assessee before ld. AO that unsecured
loan/booking money was given through companies which have
separate legal identity and the unsecured loan ... were duly
explained. It was also submitted that the treatment of unsecured
loan/investment in form of booking money in the hands of
assessee
noted by the Assessing Officer,
during the course of assessment proceedings, unsecured loans taken by
the assessee-company were increased ... unsecured loans were furnished by the assessee along
with the loan confirmations, balance-sheets, Bank statements and source
of funds of the concerned loan creditors
case the ld. CIT(A) erred in
allowing the interest on unsecured loan of Rs.27,34,728/- when the assessee
was given ample opportunity ... Ground No. 2 raised by the Revenue relates to interest on unsecured loan of
Rs. 27,34,728/- disallowed by Assessing Officer.
8. Brief facts
ground No.1 and 2 raised by
theRevenue are against treating unsecured loans Rs.43,83,994/- and Current
liability & Advances ... interest on loan the
assessee furnished statement of loan taken a utilized during the year. The assessee
had taken fresh loan
submitted during the
course of hearing that the assessee has received unsecured loans from various companies
out of which according to AO, are paper companies ... paper companies for routing the black money
in the guise of unsecured loans. According to him, these transactions are nothing but
accommodation entries and these
which the assessee claimed to have received as
unsecured loan and Rs.4,22,531/- being the interest related to the aforesaid amount of loan ... selected for
scrutiny. The AO noted that the assessee has taken unsecured loan to the tune of
Rs.44,22,531/- from M/s. Pasupati
however, the aforesaid facts necessitated enquiry into
the unsecured loans taken by the assessee. The AO claimed to have undertaken a three
step process wherein ... managed by these so-called entry operators and
that the unsecured loans obtained from these loan creditors were in the nature of
accommodation entries provided
made by the AO on account of bogus unsecured
loan u/s 68 of the Income Tax Act, 1961.
2. The department craves leaves ... made by the AO on account of bogus
unsecured loan u/s. 68 of the Income Tax Act, 1961.
3. The department craves leaves
issue involved is, the addition made on
account of receipt of unsecured loans treating it to be in the nature of unexplained
cash credit ... following documents to prove the
identity, genuineness and creditworthiness of the unsecured loans taken.
a. The PAN No. Addresses and MCA details
