Post-assessment survey without nexus to the relevant years cannot justify book rejection, suppression, or revised enhancement.

A survey conducted after the relevant assessment years could not be relied on to reject the assessee's account books or presume suppression for those years because it had no real nexus with turnover or assessability in the years under reference. On that same basis, the Additional Revising Authority's enhancement of the assessment was unsustainable, since the revisional order rested on irrelevant material. The governing principle is that post-assessment material lacking connection with the assessment years cannot support rejection of books, a presumption of suppression, or enhancement in revision.

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Issues: (i) Whether a survey conducted after the relevant assessment years could be relied upon to reject the assessee's account books and presume suppression for those years; (ii) whether the Additional Revising Authority could lawfully enhance the assessment for the assessment years in question.

Issue (i): Whether a survey conducted after the relevant assessment years could be relied upon to reject the assessee's account books and presume suppression for those years.

Analysis: The survey was held subsequent to the assessment years and, on the facts stated, disclosed nothing having any real connection with the turnover or assessability of the assessee for those years. The rejection of the books and the inference of suppression were therefore founded on material that was not relevant to the years under reference.

Conclusion: The survey could not be treated as relevant for the assessment years 1959-60 and 1960-61, and no suppression could be presumed on that basis.

Issue (ii): Whether the Additional Revising Authority could lawfully enhance the assessment for the assessment years in question.

Analysis: As the revisional order rested on an irrelevant consideration, the enhancement made on that basis was legally unsustainable.

Conclusion: The enhancement by the Additional Revising Authority was not sustainable in law.

Final Conclusion: The reference was answered against the department, and the assessee succeeded with costs.

Ratio Decidendi: A post-assessment survey having no real nexus with the relevant assessment years cannot be used as a basis for rejecting account books, presuming suppression, or sustaining enhancement in revision.

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