Estimated dhall yield addition deleted where past results were accepted and crop conditions explained variance in yield.

Estimated addition for alleged suppression of dhall yield was held unsustainable where the assessee's past and subsequent results had been accepted, and yield varied with crop quality, rainfall, and soil conditions. The record also showed that the estimated yield adopted by the assessing authority did not properly account for the disclosed husk yield. On these facts, there was insufficient basis to sustain a deficiency-based addition, and the addition was deleted in favour of the assessee.

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Issues: Whether the estimated addition made by the income-tax authorities on account of alleged suppression of dhall yield was sustainable.

Analysis: The appellant's past and subsequent results had been accepted by the Department, and the yield shown depended on factors such as crop quality, rainfall, and soil conditions. The record also indicated that the estimated yield adopted by the assessing authority did not adequately account for the appellant's disclosed husk yield. In these circumstances, there was no sufficient basis to sustain the addition made on an estimated deficiency in yield.

Conclusion: The addition of Rs. 7,575 was deleted, and the issue was decided in favour of the assessee.

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