2003 (1) TMI 234

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.... the amount of Rs. 7,41,332 is mentioned as paid on 24th Nov., 1992 and the assessee could not explain the nature and source of the expenditure. She explained that the statement of the assessee could not be recorded on this issue due to his death on 18th Dec., 1995. She has relied on decision of Hon'ble Karnataka High Court in CIT vs. P.R. Metrani (HUF) (2001) 169 CTR (Kar) 149 : (2001) 251 ITR 241 (Kar). 3. The learned counsel for the assessee argued that no addition on the basis of noting on loose paper can be made since there is no material to relate the same to any expenditure made by the assessee. He argued that no question regarding the nature and source of the alleged noting was made to the deceased assessee, who was alive for about....

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.... to explain. She argued that the son of the deceased assessee was handling all the affairs of the assessee and therefore he should be well aware of the nature and source of the noting on the loose paper. 5. We have considered the rival submissions carefully. We find that the noting on the loose paper No. 20 is as under: "paid Rs. 7,41,332 as on 24th Nov., 1992." In our considered view there cannot be any addition made in the hands of the assessee by invoking s. 69C of the Act, on the mere noting on the loose sheet reproduced above. In order to make any addition under s. 69C of the Act for unexplained expenditure, some material has to be brought on record to suggest some unexplained expenditure was incurred by the assessee and the nature ....