Unrecorded professional receipts addition fails where untested material, presumptions, and inconsistent year-wise data do not support the claim.

The addition for alleged suppression of professional receipts from indoor patients was deleted because the material relied on was not confronted to the assessee, the assessment was based largely on presumptions, and the third-party information did not reliably support additions across multiple years. The record also showed that free treatment to some patients was part of the hospital practice, undermining the basis for inferring unrecorded receipts. Reducing the addition to a percentage of the alleged receipts did not cure the defective foundation, so the full addition was held unsustainable.

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Issues: Whether the addition made on account of alleged suppression of professional receipts from indoor patients was sustainable.

Analysis: The assessment was based on computer data and inquiries said to show unrecorded receipts from certain IPD patients. The material gathered at the back of the assessee was not confronted during assessment, and the addition rested substantially on presumptions drawn from a possible reason for non-generation of bills. The finding also suffered from inconsistency, since the specific third-party information related to one assessment year, yet additions were made across multiple years. In addition, the record showed that free treatment to certain patients was a recognized feature of the hospital practice. The attempt to sustain only a percentage of the alleged receipts also could not cure the basic infirmity in the foundation of the addition.

Conclusion: The addition was not sustainable and was deleted in full.

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