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Vide section 68 in respect of any loan or borrowing in its books the assessee has to prove the three ingredients, i. e., identity of lenders, genuineness of trans- actions and creditworthiness of lenders.

Documents such as PAN, addresses, ITRs , balance sheets and bank statements of the lender result in discharge of initial onus by the assessee.

Budget 2022 provide for an additional burden upon the assessee.

And that is that the assessee has to now even demonstrate the source of money deposited into lenders bank accounts which in turn has been used by him to lend it to the assessee as loan. Hence the source of source of source is also to be proved by the assessee to the satisfaction of the AO.


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