Survey evidence cannot reject account books unless it shows suppressed transactions for the relevant assessment year.

A survey can justify rejection of account books only if it reveals suppressed transactions or other incriminating material relevant to the assessment year in issue. The date of the survey is not material by itself; the decisive point is whether the survey discloses evidence connected with that year. Here, the survey of 29 April 1964 did not contain any entry relating to assessment year 1962-63, and no other adverse material was shown. On that basis, the account books could not be rejected merely because of the survey, and the material was not usable for the 1962-63 assessment.

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Issues: Whether a survey conducted on 29 April 1964 could be used to reject the assessee's account books and support the assessment for the year 1962-63.

Analysis: The survey records did not contain any entry relating to the assessment year 1962-63. The controlling principle was that the date of survey was not material by itself; what mattered was whether the survey disclosed suppressed transactions relevant to the assessment year in question. As no incriminating material for 1962-63 emerged from the survey and no other adverse material was shown, the account books could not be rejected merely on the basis of that survey.

Conclusion: The survey dated 29 April 1964 could not be used for the assessment pertaining to the year 1962-63, and the question was answered in favour of the assessee.

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