Proviso to income-tax accounting rules needs reasoned material; unsupported yield comparisons cannot justify an addition.

Invocation of the proviso to section 13 of the Indian Income-tax Act, 1922 requires a reasoned examination of the assessee's regular accounting method and relevant material showing that income, profits and gains cannot properly be deduced from it. Unsupported comparisons of yield figures or comparable cases, and a cursory approach without consideration of the material on record, are insufficient to justify rejection of the accounts or sustain an addition.

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Issues: Whether there was material for the Tribunal to invoke the proviso to section 13 of the Indian Income-tax Act, 1922, and sustain the addition of Rs. 1,07,000 to the assessee's income.

Analysis: The Tribunal was required to decide whether the assessee's regularly employed method of accounting could be rejected and whether income, profits and gains could not properly be deduced therefrom. The record showed that the Tribunal did not properly address that central question and its order did not disclose consideration of the relevant material on which the proviso to section 13 could be applied. The Tribunal's approach to the comparative yield figures and comparable cases was also found to be unsupported by material on record, and the order was described as cursory.

Conclusion: There was no material on the basis of which the Tribunal could apply the proviso to section 13, and the addition of Rs. 1,07,000 could not be sustained.

Final Conclusion: The question referred was answered against the revenue and in favour of the assessee, with the Tribunal's basis for the impugned addition held unsustainable.

Ratio Decidendi: The proviso to section 13 of the Indian Income-tax Act, 1922 can be invoked only on a reasoned examination of the assessee's accounting method and relevant material showing that income cannot properly be deduced therefrom; unsupported or cursory findings cannot sustain the addition.

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