Young Indian v. ACIT (E) (2022)95 ITR 33 / 218 TTJ 1 (Trib) (SN) (Delhi)(Trib)

S. 69C : Unexplained expenditure-Expenditure on raising of loan-Notional and hypothetical addition-Cannot be sustained.

That the addition of Rs. 1,00,000 as an unexplained expenditure under section 69C towards raising of loan from D was a purely notional and hypothetical addition made on the hypothesis that the assessee might have incurred expenditure as commission for the accommodation entry for raising of loan from D. There was no basis for giving this hypothetical addition which was not based on any enquiry or any material on record and it could not be sustained. (AY.2011-12)