R.D. Foundation, Ghaziabad vs Ito (Exemption), Ward, Ghaziabad on 5 February, 2019
• CIT vs. Shri Ram Narain Goel (1997) 224 ITR 0180 (P&H)
20
6.3 On the other hand, Ld. Sr. DR relied upon the assessment
order and CIT(A)'s order and relied upon the decision of
Hon'ble Delhi High Court in the case of DCIT vs. NDR
Promoters P. Ltd. ITA No. 49/2018 dated 17.01.2019,
6.4 We have perused the entire material, which is before us
and we find that assessee has brought sufficient material on
record to prove that lenders have confirmed the amount of
loans, which have been given through banking channel and the
lenders were assessed to tax and that the loans have
substantially been repaid back through banking channel. We
would like to refer to various pages of the paper book relied
upon by Ld. Counsel in the synopsis at page 8-9-10. We have
gone through the various pages of the paper book as referred
by Ld. Counsel and we are of the considered opinion that not
only the identity and creditworthiness of the lenders stand
proved but also the genuineness of the loans stands proved.