Addition For unexplained expenditure cannot be made on mere presumption

Seven Jewels Vs ACIT (ITAT Mumbai) As per the provisions of section 69C of the Act, in case the assessee fails to explain the source of expenditure or part thereof to the satisfaction of the AO, such expenditure shall be considered as unexplained expenditure and be deemed to be income of the assessee. In the present case, the assessee made the payments of Rs.43,97,377, on 10th March 2015 and Rs. 43,29,549, on 18th March 2015, to M/s. Artview Gems Pvt. Ltd. in respect of the diamonds purchased by the assessee. From the statement of account of the assessee issued by the HDFC Bank, a copy of whic...