Estimated yield additions fail without tangible evidence of suppression or falsity in books of account.

Rejection of books and addition for alleged unaccounted sales based on estimated yield was held unsustainable where no cogent material showed suppression of production or falsity of accounts. The assessment relied on inferred variations in raw material consumption, electricity and furnace oil, but the estimate of 89% yield was not supported by comparable evidence. The court applied the settled principle that an addition cannot rest on pure guesswork, bare suspicion, or conjecture, and that statutory rejection of books requires tangible material. On those facts, the concurrent findings deleting the addition were not disturbed, and the assessee succeeded.

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Issues: Whether the addition made on account of alleged unaccounted sales based on an estimated yield could be sustained in the absence of cogent material, and whether rejection of the books of account on such basis was justified.

Analysis: The assessment rested on an estimated production yield and inferences drawn from variations in consumption of raw material, electricity and furnace oil. The appellate authority and the Tribunal found that no cogent evidence had been brought on record to show suppression of yield or any unaccounted sales, that the estimate of 89% yield had not been supported by comparable material, and that the rejection of books under the statutory scheme could not rest on conjecture alone. The decision follows the settled principle that an assessment cannot be made on pure guesswork or bare suspicion and must be supported by material evidence; absent such material, concurrent factual findings deleting the addition do not warrant interference.

Conclusion: The addition based on alleged suppression of yield and unaccounted sales was not justified, and the assessee succeeded.

Ratio Decidendi: Rejection of books and addition on estimated yield cannot be sustained unless the assessment is supported by tangible material showing suppression or falsity of accounts, and not by mere suspicion or conjecture.

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