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Issues: Whether, after rejecting the assessee's method of accounting, the Income Tax Officer was free to adopt his own basis of computation and whether an addition could be made towards kasar without evidence.
Analysis: The assessee's accounting method was not bound to be accepted merely because the stock and purchases could be checked from Government sources. Once that basis was rejected, the assessing authority was entitled under the Act to adopt another basis for computation, but the assessment had to disclose the basis on which the figures were reached. The addition made towards kasar could not stand on mere assumption that liquor sellers generally sold by short measure, because there was no evidence of such practice by the assessee. The Commissioner therefore had to reassess the figure on a proper footing.
Conclusion: The question was answered in the affirmative, but the assessee succeeded on the point that no addition could be made for kasar without evidence.
Ratio Decidendi: After rejecting an assessee's accounting basis, the revenue may adopt another reasonable basis of computation, but any addition to income must rest on evidence and cannot be founded on unsupported assumptions of wrongdoing.