Addition under S. 68 cannot be made for loan taken in earlier years

ITO Vs. Nasir Khan J. Mahadik (ITAT Mumbai)-Mumbai ITAT has in the following case deleted the additions made on account of opening balances of unsecured loans and the notional interest on such loans. The Tribunal held that only fresh loans or additions to the loans during the year in question can be considered for the purpose of addition. Previous years loans cannot be added to subsequent year’s income by claiming them to be unexplained. In this case The AO has made arbitrary additions during assessment proceedings, which the Tribunal has deleted by taking strict note of the same and the...