Turnover enhancement requires cogent evidence of undisclosed transactions; non-production of books during survey alone is insufficient.

Non-production of books of account during a survey may justify rejection of the books and a best-judgment assessment, but it does not alone justify enhancing disclosed turnover. Enhancement for alleged undisclosed purchases or sales requires discrepancies or other cogent adverse material found during the survey. In the absence of such material, turnover cannot be increased on presumption alone, and the disclosed turnover must be accepted.

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Issues: Whether disclosed turnover could be enhanced merely because books of account were not produced during survey, without cogent adverse material supporting undisclosed purchases and sales.

Analysis: Non-production of books of account at the time of survey justified their rejection and a best-judgment assessment, but did not by itself permit enhancement of turnover. No discrepancy or other adverse material was found during the survey to support estimation of undisclosed purchases or sales.

Conclusion: The disclosed turnover was required to be accepted; enhancement based solely on presumption in the absence of cogent material was impermissible, in favour of the assessee.

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