Income estimation on bank deposits remitted for fresh verification after assessee produced supporting evidence.

Estimation of income at 8% of total deposits could not be finalized on the existing record because the assessee later placed material suggesting the deposits comprised freight receipts, cattle transactions, commission income, and redeposits of earlier withdrawals. As the explanation before the Assessing Officer had covered only part of the receipts, the Tribunal held that the evidence required verification and further examination before any final addition could be sustained. The matter was remitted to the Assessing Officer for fresh adjudication in accordance with law, and the appeal was allowed for statistical purposes.

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Issues: Whether the issue relating to estimation of income at 8% of the total deposits required fresh adjudication after verification of the assessee's evidence.

Analysis: The record showed that the assessee's explanation before the Assessing Officer covered only a limited part of the receipts, while the later proceedings placed voluminous material before the Tribunal to support the claim that the deposits represented freight receipts, cattle transactions, commission income, and redeposits of earlier withdrawals. In these circumstances, the material on record required verification and examination before a final determination could be made on the estimated addition.

Conclusion: The issue was remitted to the Assessing Officer for fresh adjudication in accordance with law after considering the assessee's submissions and evidence, and the appeal was allowed for statistical purposes.

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