Unproved nexus and inadmissible electronic evidence sustained the addition in the assessee's income challenge.

The addition of business receipts was sustained because the assessee failed to produce a credible reconciliation linking amounts received from companies to alleged payments to landowners. The claimed additional evidence and hard disk did not establish the required nexus between the companies, vendors and assessee, and the relevant sale deeds and supporting details were not produced. The Tribunal also declined remand, holding that the additional evidence was not validly admitted under the Appellate Tribunal Rules and the hard disk was not certified as an electronic record under the Information Technology Act. The challenge to deletion of the addition therefore failed.

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Issues: Whether the addition of Rs. 72 lakhs, treated as business receipts and sustained as additional income, was justified and whether the assessee was entitled to rely on additional evidence and a hard disk to seek deletion of the addition.

Analysis: The assessee failed to produce a credible reconciliation linking the amounts received from the companies with the alleged payments to the landowners. The claimed additional evidence and hard disk did not establish the necessary nexus between the companies, the vendors and the assessee, nor were the corresponding sale deeds and supporting details produced. The request for remand was also declined since the additional evidence was not validly admitted under the Appellate Tribunal Rules and the hard disk was not certified as an electronic record in terms of the Information Technology Act.

Conclusion: The addition of Rs. 72 lakhs was rightly sustained and the assessee's challenge failed.

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