Estimated cable subscription receipts addition remanded after inadequate factual inquiry and failure to consider past business history.

An addition based on estimated cable subscription receipts could not be sustained where the estimate rested on information collected after the business had closed and did not adequately consider the assessee's past business history or earlier-year receipts. The factual foundation was therefore held insufficient, and the matter was remanded for fresh adjudication after obtaining the relevant past records from the entertainment tax department and giving the assessee a proper opportunity of hearing.

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Issues: Whether the addition made on estimated cable subscription receipts was sustainable and whether the matter required restoration to the Assessing Officer for fresh consideration.

Analysis: The estimated receipts were based on information collected after the business had already been closed, and the record did not sufficiently account for the assessee's past business history or the receipts shown in earlier years. In these circumstances, the factual basis for the estimate was found inadequate, and the issue was considered fit for reconsideration after obtaining the relevant past records from the entertainment tax department and after granting the assessee a proper opportunity of hearing.

Conclusion: The addition was not finally sustained and the matter was remanded to the Assessing Officer for fresh adjudication.

Ratio Decidendi: An income addition based on post-closure estimates and incomplete factual inquiry cannot be sustained without considering the assessee's past history and the relevant records, and the matter may be restored for de novo examination.

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