Section 69A addition fails without specific nexus or corroborative evidence linking alleged accommodation entries to unexplained money.

An addition under section 69A based on alleged accommodation entries and bogus capital gains was unsustainable where the record showed no specific material linking the assessee to the alleged entry provider or any corroborative evidence of unexplained money. General investigation inputs, without identification of the relevant transactions, scrips, dates, routing of funds, or matching credit entries in the assessee's bank statements, were insufficient. The share transactions reflected only a nominal short-term capital gain already offered to tax, and no independent inquiry established that unrecorded money was introduced as capital gains. The deletion of the addition was therefore upheld.

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Issues: Whether the addition made under section 69A on the basis of alleged accommodation entries and bogus capital gains was sustainable in the absence of specific material linking the assessee to the alleged entry provider and corroborative evidence of unexplained money.

Analysis: The addition rested on general investigation information alleging a stock market accommodation-entry racket, but no live nexus was established between the assessee and the alleged operator. The assessment order did not identify the exact transactions, the specific scrips giving rise to the alleged amounts, the dates or manner of the supposed routing of funds, or any corresponding credit entries in the assessee's bank statements. The assessed share transactions disclosed only a nominal short-term capital gain already offered to tax, and no independent inquiry or corroborative material was brought on record to show that the assessee introduced unaccounted money in the guise of capital gains. An addition under section 69A requires cogent material showing ownership of unrecorded money and the absence of a satisfactory explanation.

Conclusion: The addition under section 69A was held unsustainable and the deletion of the addition was upheld, in favour of the assessee.

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