26AS corroboration and deductor confirmations can sustain tax additions when the assessee offers no contrary evidence.

Receipts reflected in 26AS, Form-16A and deductor confirmations were treated as reliable corroboration where the assessee had not maintained or audited books, did not dispute the entries at assessment stage, and produced no contrary evidence. The revisional authority's refusal to interfere under Section 264 was upheld because the alleged lack of further enquiry and denial of opportunity did not establish a breach of natural justice on the record. In writ jurisdiction, the revisional finding was not displaced, and the challenge failed in favour of the Revenue.

---

---

Issues: Whether the revisional order under Section 264 of the Income-tax Act, 1961 was liable to be interfered with for alleged non-enquiry and denial of opportunity regarding the receipts reflected in the 26AS statement and confirmed by the deductors.

Analysis: The assessee had not maintained books of account and had not had them audited. The assessing authority had made enquiries from the three concerns, which confirmed the payments and furnished TDS particulars. The 26AS statement, Form-16A and the assessee's own conduct, including failure to dispute the entries at the assessment stage or produce contrary evidence, supported the addition. The revisional authority also attempted verification from one concern, but no response was received. The claim of violation of natural justice was rejected because the assessee had been confronted with the material during assessment and did not rebut it. In writ jurisdiction, no ground was found to displace the revisional finding.

Conclusion: The challenge to the revisional order failed and the decision stood in favour of the Revenue.

Ratio Decidendi: Where receipts are corroborated by departmental 26AS data, deductor confirmations and TDS records, and the assessee neither maintains proper accounts nor produces contrary evidence, a revisional order refusing interference does not warrant writ correction merely on an allegation of inadequate enquiry.

---