Addition can not be made merely on the basis of assumption

RELEVANT PARAGRAPH 1. There being difference of opinion between the Members, the following questions were referred for the opinion of the Third Member:- 1. Whether, in the given facts and circumstances of the case, addition of Rs. 2,95,000/- on account of alleged undisclosed advance is justified or not ? 2. Whether, in the given facts and circumstances of the case, addition of Rs. 1,00,000/- for alleged unexplained stock found during the survey is justified or not? 3. Whether, since learned JM has admitted the quantum addition, the corresponding penalty levied u/s 271(1)(c) is to be cancelled/...