Account books cannot be rejected on prior-year survey material alone when no incriminating evidence exists for the relevant year.

Account books could not be rejected where the survey material related to an earlier period and did not disclose incriminating evidence for the relevant assessment year. Adverse findings for prior years, without current-year material, were insufficient to justify rejection of the books in toto. Rejection based only on that earlier material amounted to suspicion rather than proof, so the accounts were accepted and the issue was answered in favour of the assessee.

---

---

Issues: Whether there was material to reject the account books or to hold that they could not be accepted in toto.

Analysis: The survey relied upon related to an earlier period and did not disclose incriminating material for the assessment year in question. Findings adverse to the assessee for earlier years could not, by themselves, justify rejection of the account books for the relevant year. Rejection of the accounts on that basis rested on no material and amounted only to suspicion.

Conclusion: The account books could not be rejected on the material available, and the question was answered in the negative in favour of the assessee.

---