आदेश /ORDER

PER ABY T. VARKEY, JM:

This is an appeal preferred by the assessee company against the order of the Learned Commissioner of Income Tax (Appeals) -52, Mumbai [ in short „ld. CIT(A)‟] dated 31.07.2023 for AY. 2018-19. The sole grievance of the assessee is against the action of the Ld. CIT(A) confirming the addition of Rs.80,00,000/- on account of unsecured loan u/s 68 of the Income Tax Act, 1961 [ in short „the Act‟] .

2. The facts relating to this issue are that, according to the AO, details of unsecured loan were found and seized in the form of loose paper ID marked Annexure A1, Page 50 at the residential premises of Mr. Tabrez Shaikh. The AO stated that this sheet contained names of several lenders who had advanced loans to the entities & individuals of Rubberwala Group. According to the AO, the content of this seized material was incriminating in nature. The AO in the assessment order has extracted the answers given in the statement of Mr. Tabrez Shaikh recorded in the course of search, wherein he was confronted with the details of these lenders, to which he did not give any proper reply. According to the AO, the subsequent questions were also posed with reference to