Addition u/s 69C simply based on scribbling notes without any other evidences is unwarranted

Krishna D. Pawar Vs ITO (ITAT Mumbai) ITAT Mumbai held that addition towards unexplained expenditure u/s 69C of the Income Tax Act simply on the basis of scribbling note without any other oral/ documentary evidences is unwarranted and unsustainable. Facts- During the course of assessment, AO noted that assessee has made payment of Rs. 95 Lakhs to Singhad Technical Education Society (STES) for the admission of his daughter. Accordingly, AO issued show cause notice asking as to why Rs. 95 Lakhs paid as capitation fees to STES for admission of his daughter should not be added to his total income ...