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of Addition u/s 68 - onus prove - non-compliance by the lender - Treating the loan transaction as a mere accommodation entry - The Tribunal observed that loose paper found in the course of search do not constitute incriminating material belonging to the assessee per se. As noted, the AO himself has found the other transactions mentioned in the loose paper to be correct and worthy of acceptance. - The Tribunal found that the transactions were conducted through proper banking channels with sufficient documentation and repayment indicating genuine transactions. Furthermore, the Tribunal held that additions based on assumptions or extrapolations without tangible material for the specific assessment year were not permissible, leading to the dismissal of the Revenue's appeal.
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