ITAT Kolkata dismissed all of the Revenue’s appeals for AYs 2017-18 to 2022-23. It deleted the Section 68 additions for unsecured loans, finding that the assessee had proved the loans with MCA data, confirmations, bank statements and repayment with TDS, and that an unexplained Excel file and statements could not sustain the additions.
The Tribunal also upheld the deletion of the alleged cash loans, the Section 50CA addition on share buyback, the ad hoc expense disallowances and the ₹4 crore penalty under Section 271D, all of which rested on third-party search material without corroboration.