Estimated business income from cash deposits reduced to 10% after later returns showed lower disclosed margins.

Cash deposits of a wholesale potato dealer were treated as business turnover, but the Tribunal found that estimating income at 25% was excessive. It relied on the assessee's later returns, where income was disclosed on a presumptive basis at 10% and in subsequent audit years at below 10%, to align the assessment for the impugned year with the highest rate later shown by the assessee. The income was therefore directed to be assessed at 10% instead of 25%, granting partial relief.

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Issues: Whether the assessee's income from cash deposits was liable to be estimated at 25% or at 10%.

Analysis: The assessee was a wholesale dealer in potatoes and had deposited cash during the relevant assessment year. The Assessing Officer treated the cash deposits as business turnover and estimated income at 25%, which was affirmed in appeal. The Tribunal compared the assessee's subsequent returns, noting that income for one later year was disclosed on presumptive basis at 10% and for later years, after audit, at less than 10%. On that basis, the Tribunal held that the higher estimate of 25% was excessive and that the income for the impugned year should be aligned with the maximum percentage subsequently disclosed by the assessee.

Conclusion: The income was directed to be assessed at 10% and not at 25%, resulting in partial relief to the assessee.

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