Income Additions Require Evidence, Not Assumptions: Unsupported 2% Commission on Accommodation Entries Deemed Unsustainable.

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....Accommodation entries - Estimation of income - the addition cannot be made on the basis of any hypothesis presumption albeit it has to be based on evidences or material or enquiry conducted. The addition here in this case has purely been made on surmises and presumption that assessee might have earned 2% commission on accommodation entry. This approach is unsustainable in law and on facts. At least, there has to be a concrete finding with material that assessee was found to be carrying out shady accommodation entry transaction. - AT....