Income Tax Appellate Tribunal, Rajkot Bench, Rajkot

Parties Involved

Facts Summary

The appeal filed by the Revenue pertains to the assessment year 2023-24. The appeal is directed against the order under section 250 of the Income-tax Act, 1961 passed by the National Faceless Appeal Centre (NAC) Delhi/Commissioner of Income-tax (Appeals) [in short 'NFAC/Ld.CIT(A)'], dated 28.08.2025. The assessee, Tanvi Exports India Limited, was required to explain the source of the source of an unsecured loan. The assessee had submitted documents to explain the source but had not submitted documents to explain the source of the source. The learned DR for the Revenue submitted that the matter may be restored back to the file of the Assessing Officer with the direction to the assessee to submit the documents and evidences to explain the source of the source. The counsel for the assessee sought more time to file additional documents and evidences to explain the source of the source.…

Legal Issues

• 1. Whether the assessee needs to explain the source of the source of the unsecured loan?

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

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