DCIT v. Rabo India Finance Ltd. (2021) 189 ITD 420 (Mum.) (Trib.)

S. 69 : Unexplained investments-A Non Banking Finance Company (NBFC) engaged in providing loans and investment activities in India-Loan was not advanced to Foreign Company-Addition was held to be not justified.

Dismissing the appeal of the revenue the Tribunal held that the findings of Assessing Officer that assessee had advanced loans from undisclosed sources was merely based on surmises and conjectures. (AY. 2006-07, 2007-08)