Addition for Unsecured Loans Without PAN: ITAT Grants Partial Relief and Remands Matter for Verification of Submitted Documents

This ITAT order addresses addition for unsecured loans where PAN details were missing. The AO treated receipts as unexplained income; CIT(A) partly confirmed the addition. On appeal, ITAT granted partial relief, noting that while absence of PAN warrants caution, documentary evidence existed and deserved verification. The tribunal remanded the case for AO to verify lender identity, creditworthiness, and genuineness of transactions before concluding. The ruling highlights procedural fairness, fact-specific inquiry, and the principle that additions under Section 68 cannot be made mechanically without examining evidence and granting reasonable opportunity to the assessee.