Estimated trading addition cannot stand merely for low gross profit and missing quantity details without rejection of books.

Estimated trading addition based only on a low gross profit rate and absence of quantitative details was not sustainable where the record did not show that sales, purchases, or stock were unsupported or unverifiable. The Tribunal noted that mere dissatisfaction with declared gross profit did not, by itself, justify rejection of book results or invocation of the proviso to section 145(1) without a cogent finding that the trading account could not be accepted. The addition was deleted.

---

---

Issues: Whether the addition made by estimating sales and applying a higher gross profit rate to the trading account could be sustained on the basis of want of quantitative details and the application of the proviso to section 145(1).

Analysis: The Tribunal found that the addition rested only on the view that the gross profit shown was low and that the trading account lacked quantities. There was no material to show that sales, purchases, or stock details were not vouched, nor was there any cogent finding that the book results or trading results could not be accepted. The record did not support the conclusion that the proviso to section 145(1) was attracted merely because the declared gross profit rate appeared unsatisfactory.

Conclusion: The addition was held to be unsustainable and was deleted.

---