Mere suspicion of transaction cannot conclude unsecured loan as unexplained

ACIT Vs Harvansh P. Chawla (ITAT Delhi) Facts- Based on the email from Mr. Michael Boettcher, AO alleged undisclosed income of $7,000,000 (i.e., INR 28,00,00,000. Unsecured loan was received by the Assessee from various parties and the addition was made by the AO treating the same as unexplained income. Conclusion- Undisclosed income – it is concluded that there is no liabilities on the part of the assessee and the revenue could not bring about any cogent material to prove the allegations. Unsecured loan– It is seen that merely because the Lender Company had substantial funds through bor...