Issues: Whether penalty for concealment of income or furnishing inaccurate particulars was sustainable under Section 271(1)(c) of the Income-tax Act, 1961.

Analysis: Section 271(1)(c) creates distinct defaults of concealment of particulars of income and furnishing inaccurate particulars. A penal provision requires clear identification and proof of the particular default invoked. Furnishing inaccurate particulars concerns incorrect, erroneous, or false details supplied in the return; mere non-disclosure, if established, falls under a different default. The penalty order inconsistently referred to concealment and furnishing inaccurate particulars without conclusively identifying either default. Explanation 1 was also inapplicable because an explanation had been furnished during assessment, was not found false, and the addition was computed by adopting figures contained in that explanation. The civil nature of penalty removes the requirement of mens rea but does not make penalty automatic upon an addition or dispense with satisfaction of the statutory conditions.

Conclusion: The conditions for imposition of penalty under Section 271(1)(c), read with Explanation 1, were not established, and the penalty could not be sustained.

Issues: Whether a direct appeal to the Tribunal against an Assessing Officer's rectification order under section 154 was maintainable.

Analysis: The admitted position was that the intended challenge was to the Assessing Officer's rectification order and that no appeal against that order had been filed before the Commissioner (Appeals). The reference in the appeal form to the Commissioner (Appeals)' order was acknowledged to be erroneous. The statutory appellate forum had therefore not been approached in the prescribed sequence.

Conclusion: A direct appeal to the Tribunal against the Assessing Officer's order under section 154 is non-maintainable; the challenge must first be brought before the Commissioner (Appeals).

Issues: (i) Whether the seized cash was rightly treated as unexplained money under Section 69A of the Income-tax Act, 1961; (ii) Whether the special rate under Section 115BBE of the Income-tax Act, 1961 was applicable; (iii) Whether penalty under Section 271AAB(1A)(b) of the Income-tax Act, 1961 was sustainable.

Issue (i): Whether the seized cash was rightly treated as unexplained money under Section 69A of the Income-tax Act, 1961.

Analysis: Section 69A permits money owned by an assessee to be deemed income where it is not recorded in the books and its nature and source are not satisfactorily explained. The asserted source remained unsupported by a cash book, ledger, income-expenditure statement, or other corroborative material. A bare and unsubstantiated explanation did not shift the evidentiary burden to the Revenue.

Conclusion: The addition of Rs. 25 lakh as unexplained money under Section 69A of the Income-tax Act, 1961 was sustained, against the assessee.

Issue (ii): Whether the special rate under Section 115BBE of the Income-tax Act, 1961 was applicable.

Analysis: The special rate under Section 115BBE applies to income validly assessed as unexplained money under Section 69A. As the unexplained-money addition was sustained and no basis was shown to displace its application, the special-rate taxation followed.

Conclusion: Taxation under Section 115BBE of the Income-tax Act, 1961 was sustained, against the assessee.

Issue (iii): Whether penalty under Section 271AAB(1A)(b) of the Income-tax Act, 1961 was sustainable.

Analysis: The penalty was linked to the sustained addition arising from the search-related cash seizure. No material was placed to justify interference with the penalty determination.

Conclusion: The penalty of Rs. 15 lakh under Section 271AAB(1A)(b) of the Income-tax Act, 1961 was sustained, against the assessee.

Final Conclusion: The determinations concerning unexplained cash, consequential special-rate taxation, and search-related penalty remain operative.

Ratio Decidendi: For Section 69A purposes, a bare assertion of a source, without supporting books or evidence, does not satisfactorily explain seized cash.

Issues: Whether the claimed exempt long-term capital gain from sale of equity shares was established as a genuine transaction so as to displace the addition under Section 68 of the Income-tax Act, 1961.

Analysis: The documentary trail of merger-based allotment, dematerialisation and sale through a recognised intermediary did not, by itself, establish the genuineness of the claim. The scrip was subject to investigation findings, and its abnormal price movement, trading pattern and lack of corresponding financial fundamentals were inconsistent with ordinary market behaviour. The assessee did not furnish material demonstrating the company's intrinsic financial strength or rebutting the adverse findings concerning the scrip. No new facts or evidence were produced to dislodge the appellate findings.

Conclusion: The long-term capital gain claim was not proved to be genuine, and the addition under Section 68 of the Income-tax Act, 1961 was sustained against the assessee.

Issues: (i) Whether expenditure recorded in the books and paid through banking channels could be added as unexplained expenditure merely because vendors did not respond to verification notices or allegedly did not file returns; (ii) Whether the first appellate authority violated the rules governing additional evidence by deciding the appeal without obtaining a remand report.

Issue (i): Whether expenditure recorded in the books and paid through banking channels could be added as unexplained expenditure merely because vendors did not respond to verification notices or allegedly did not file returns.

Analysis: The legal framework for unexplained expenditure concerns the source of expenditure, rather than a mere doubt about the authenticity of an expense. The expenditure was recorded in unrejected books, paid through banking channels, and supported by vendor identity particulars, invoices, ledger accounts, agreements, GST records and transaction data. Non-response by vendors to verification notices and their subsequent return-filing status did not establish either that the expenditure was fictitious or that its source was unexplained. Once the assessee supplied contemporaneous documentary evidence, the evidentiary burden required the Revenue to bring positive material discrediting the transactions. The verification notices issued by the Assessing Officer did not, without further investigation or adverse material, meet that burden.

Conclusion: The addition as unexplained expenditure was unsustainable; the deletion of the addition was affirmed, in favour of the assessee.

Issue (ii): Whether the first appellate authority violated the rules governing additional evidence by deciding the appeal without obtaining a remand report.

Analysis: The rule governing additional evidence applies only where material not previously produced is admitted by the first appellate authority. No specific document qualifying as additional evidence was identified. The material relied upon had either been furnished during assessment proceedings or was an analysis or explanation of material already on the assessment record; consequently, the requirement of a remand report was not triggered.

Conclusion: There was no violation of the rules governing additional evidence, and a remand report was unnecessary, in favour of the assessee.

Final Conclusion: Documented business expenditure reflected in unrejected books cannot be treated as unexplained solely on third-party non-compliance with verification notices, absent positive material discrediting the transactions.

Ratio Decidendi: Where the source of expenditure is evidenced by unrejected books and banking records, third-party non-response to verification notices, without independent adverse material, does not justify an addition for unexplained expenditure.

Issues: Whether the cash deposits in the bank account were satisfactorily explained by the cash-flow statement and prior withdrawals.

Analysis: The opening cash balance was unsupported by evidence of the preceding year's closing cash. The purported withdrawals during April and May 2016 were cheque payments and could not constitute cash available for later deposits. However, deposits of Rs. 18 lakhs on 1 July 2016 were supported by equivalent withdrawals on 29 and 30 June 2016. The interim deposits of Rs. 8.10 lakhs and agricultural expenditure of Rs. 5 lakhs remained unexplained.

Conclusion: The addition was restricted to Rs. 13.10 lakhs, with consequential relief to the assessee.

Issues: Whether the value of materials supplied free of cost by the service recipient forms part of the gross value for service-tax determination and for denial of the 67% abatement.

Analysis: Under the service-tax valuation framework and the applicable abatement notification, the gross amount charged cannot include the value of materials supplied free by the recipient unless such inclusion is specifically provided by law. The binding position confirms that free supplies of steel and cement are not part of the consideration charged by the service provider.

Conclusion: The cost of materials supplied free of cost by the service recipient does not form part of the gross value of taxable services; denial of the 67% abatement on that basis is unsustainable.

Issues: Whether an application for registration under section code 4A could be rejected as non-maintainable solely because returns were filed in Form ITR-7.

Analysis: Section code 4A corresponds to item (B) of section 12A(1)(ac)(vi), which requires that no income or part of income should previously have been excluded from total income under sections 11 or 12 or the specified provisions of section 10(23C). The statutory test is actual exclusion of income, not the mere choice of return form. Form ITR-7 may be relevant evidence, but cannot conclusively establish availment of exemption without examination of the returns, relevant schedules, computations, and processing or assessment records.

Conclusion: Mere filing of Form ITR-7 does not conclusively prove that exemption under sections 11 or 12 was availed; the application cannot be treated as non-maintainable solely on that basis.

Issues: Whether gross profit estimated on unrecorded sales inferred solely from a shortage of stock constitutes undisclosed income for levy of penalty under section 271AAB of the Income-tax Act, 1961.

Analysis: Explanation (c) to section 271AAB requires the income to be represented by money, bullion, jewellery, other valuable article or thing, or an entry, document or transaction found during the search. A stock shortage is an absence revealed by comparison of physical inventory with book stock, rather than material found during the search. The alleged unrecorded sales and the resulting income rested on inference, followed by estimation through application of the gross-profit rate; no search material evidencing an outside-the-books sale or false expense entry was identified. Penalty proceedings are independent of assessment proceedings, and acceptance of an assessment addition is not conclusive of undisclosed income. As a penal provision, section 271AAB requires strict construction, with the burden on the Revenue to establish the statutory conditions.

Conclusion: The estimated gross profit did not constitute undisclosed income within Explanation (c) to section 271AAB, and the penalty levied under section 271AAB(1A)(b) was unsustainable.

Issues: Whether a difference between turnover disclosed in service-tax returns and revenue reported under the Income-tax Act, 1961, justified an addition where real-estate revenue was recognised under the Percentage of Completion Method.

Analysis: Service tax under the erstwhile regime applied to advances received, whereas income under the Income-tax Act, 1961 was to be computed according to the regularly followed mercantile method and the Percentage of Completion Method under Section 145(1). Amounts received as customer advances were reflected as liabilities until the relevant stage of project completion. The audited books, financial statements and project-wise workings supported the revenue recognised for the year. No discrepancy in the books was established, and the books were not rejected under Section 145(3). The difference between service-tax turnover and income-tax turnover therefore represented a timing and accounting-basis difference.

Conclusion: The mismatch could not be treated as unaccounted turnover or taxable income, and deletion of the addition was sustained.

Issues: Whether regular bail should be granted in the alleged offence concerning wrongful availment and utilisation of input tax credit.

Analysis: The complaint had been submitted; the applicant had no criminal antecedents, had remained in custody since 15.06.2026, and the trial was likely to take time.

Outcome: Regular bail granted.

Issues: Whether penalty for contravention of Section 269SS could be imposed merely because cash deposits in the bank account were treated as unexplained, without evidence establishing acceptance of a loan, deposit, or specified sum from another person.

Analysis: Penalty provisions require strict construction. For penalty under Section 271D, the competent authority must first record specific findings establishing the conditions under Section 269SS: a transaction with an identifiable person, its character as a loan, deposit, or specified sum, and satisfaction of the monetary threshold. The burden shifts to the assessee under Section 273B only after these foundational conditions are established. Mere cash deposits in a bank account, or rejection of the explanation of their source in quantum proceedings, does not by itself establish a violation of Section 269SS.

Conclusion: In the absence of evidence identifying any person from whom a loan, deposit, or specified sum was accepted in cash, the penalty under Section 271D was not sustainable; the deletion of the penalty was upheld in favour of the assessee.

Issues: (i) Whether stock-exchange charges imposed for operational and procedural lapses are deductible as business expenditure notwithstanding Explanation 1 to section 37(1) of the Income-tax Act, 1961.
(ii) Whether penalty under section 270A of the Income-tax Act, 1961 is leviable for a deduction of health and education cess claimed before the retrospective insertion of Explanation 3 to section 40(a)(ii) of that Act.

Issue (i): Whether stock-exchange charges imposed for operational and procedural lapses are deductible as business expenditure notwithstanding Explanation 1 to section 37(1) of the Income-tax Act, 1961.

Analysis: Explanation 1 excludes expenditure incurred for an offence or a purpose prohibited by law. The charges arose under stock-exchange bye-laws and regulations for delivery, reporting, deposit, margin and client-code lapses. Their substance was compensatory and regulatory, rather than a statutory sanction for an offence; classification in the tax-audit report as a penalty or fine did not alter that character.

Conclusion: The charges are allowable business expenditure and do not attract Explanation 1 to section 37(1). This issue is decided in favour of the assessee.

Issue (ii): Whether penalty under section 270A of the Income-tax Act, 1961 is leviable for a deduction of health and education cess claimed before the retrospective insertion of Explanation 3 to section 40(a)(ii) of that Act.

Analysis: Explanation 3 to section 40(a)(ii), introduced by the Finance Act, 2022 with retrospective operation, subsequently removed deductibility of health and education cess. When the returns were filed, the claim followed the prevailing judicial interpretation and was made with full disclosure of material facts. A bona fide disclosed claim cannot constitute under-reporting or misreporting merely because a later retrospective amendment makes it inadmissible; the saving mechanism in section 155(18) further supports that position.

Conclusion: Penalty under section 270A is not leviable for the cess claim and is deleted. This issue is decided in favour of the assessee.

Final Conclusion: The computation must give effect to the deductibility of regulatory stock-exchange charges, and the disclosed cess claim made under the then-prevailing legal position carries no liability to penalty.

Issues: (i) Whether additions under section 69A could be sustained despite the DVO report finding that the declared values corresponded with fair market value; (ii) Whether penalties under section 271B for failure to obtain audit could be sustained in the absence of proof of reasonable cause.

Issue (i): Whether additions under section 69A could be sustained despite the DVO report finding that the declared values corresponded with fair market value.

Analysis: The reference for valuation resulted in a DVO report finding that the declared sale and purchase values of the properties matched their fair market value. This factual position remained unrebutted. The binding nature of the favourable DVO report precluded the departmental authorities from sustaining contrary unexplained-money additions.

Conclusion: The section 69A additions are deleted, in favour of the assessees.

Issue (ii): Whether penalties under section 271B for failure to obtain audit could be sustained in the absence of proof of reasonable cause.

Analysis: The assessees neither pleaded nor established a reasonable cause for failure to have their books of account audited due to circumstances beyond their control.

Conclusion: The section 271B penalties are sustained, against the assessees.

Final Conclusion: The uncontroverted valuation findings govern the determination of the disputed property values, while failure to prove reasonable cause leaves the audit-default penalties intact.

Issues: Whether the unaccounted cash consideration recorded in seized digital material could be assessed as unexplained investment despite denial of payment, non-grant of cross-examination, co-ownership of the property, registration in a subsequent year, and presumptive-tax treatment.

Analysis: Section 69 permits assessment where the assessee does not satisfactorily explain the source of an investment. The seized digital records from the seller specifically matched the unit and purchaser details and were supported by statements recorded under Section 132(4) from key personnel admitting unaccounted cash transactions. The material was disclosed to the assessee, whose bare denial did not displace the documentary evidence or explain the source of the cash payment. Cross-examination was not indispensable where the addition rested principally on seized and corroborated documentary material rather than statements alone. The absence of departmental action concerning another flat or co-owner was immaterial to the evidentiary material relating to the concerned property. Presumptive-tax treatment and absence of an obligation to maintain books did not relieve the assessee from explaining the source of the investment, and the later registration date did not affect the finding that the cash payment was made in the relevant year.

Conclusion: The cash payment of Rs. 12,50,000 was assessable as unexplained investment under Section 69; the challenge based on denial of cross-examination and related objections failed.

Issues: Whether a contractual claim for recovery of GST amounts paid to a service provider, following reversal of input tax credit, is ex facie non-arbitrable at the stage of appointment of an arbitrator under Section 11(6) of the Arbitration and Conciliation Act, 1996.

Analysis: At the Section 11 stage, the enquiry is confined to the prima facie existence of an arbitration agreement. The admitted arbitration clause covered disputes arising under the contractual engagement. A claim concerning reimbursement or the ultimate inter se incidence of an indirect-tax amount paid under a contract is a dispute in personam between the contracting parties; it neither determines tax liability vis-a -vis the revenue nor intrudes upon the State's sovereign taxing functions. Objections concerning jurisdiction and arbitrability remain available before the arbitral tribunal under Section 16 of the Arbitration and Conciliation Act, 1996.

Conclusion: The reimbursement claim was not manifestly non-arbitrable, and a sole arbitrator was appointed, with objections on jurisdiction and arbitrability reserved for determination by the arbitral tribunal.

Issues: Whether the unsecured loans received by the assessee were liable to be treated as unexplained cash credits under Section 68.

Analysis: Section 68 requires the assessee to establish the identity of the creditor, creditworthiness, and genuineness of the transaction. The documentary evidence, including financial particulars, banking records, confirmations, and repayment details, discharged the assessee's burden of proof. The lenders' low reported income and the absence of formal loan agreements, without contrary material disproving the evidence, were insufficient to negate their creditworthiness. The Revenue did not bring material to displace the factual findings accepting the loans as genuine.

Conclusion: The loan receipts stood satisfactorily explained under Section 68, and the issue is decided in favour of the assessee.

Issues: Whether a battery-integrated rear cover/back cover assembly for tablet PCs is classifiable as a part of an automatic data processing machine under tariff item 8473 30 99 or as a lithium-ion accumulator under tariff item 8507 60 00.

Analysis: Heading 8473 is a residual parts heading and expressly excludes covers, carrying cases and the like. Under Note 2(a) to Section XVI, an article specifically covered by a heading of Chapter 84 or Chapter 85 must be classified in its own heading before resorting to a general parts heading. Note 3 to Chapter 85 extends heading 8507 to electric accumulators presented with ancillary components that contribute to their operation or protection, including a portion of the protective housing of the goods in which they are used. The lithium-ion battery supplied the assembly's active power function, while the thermal pads, conductive cloth, foam, bracket, waterproofing arrangements, middle frame and back cover secured, protected and provided thermal management for the battery. The integrated components consequently had the functional nexus contemplated by Note 3 to Chapter 85.

Conclusion: The battery-integrated rear cover/back cover assembly is classifiable under tariff item 8507 60 00 as a lithium-ion accumulator, and not under tariff item 8473 30 99. The ruling is against the assessee.

Ratio Decidendi: A machine component specifically covered by a tariff heading must be classified under that specific heading where its ancillary and protective components fall within the extended scope of that heading, notwithstanding its dedicated use in another machine.

Issues: Whether approval under section 80G could be denied because the trust's objects included construction of a temple and worship activities, and because expenditure on such activities allegedly exceeded the permissible limit.

Analysis: The trust had already received approval under section 12AB on substantially identical objects. Its objects also included relief operations without distinction of caste, creed or religion. The construction or maintenance of a place of worship and worship-related activities do not by themselves establish that the trust's dominant purpose is religious. Denial of approval requires material indicating that the activities are intended to segregate beneficiaries on religious grounds, propagate a particular belief to the exclusion of others, or otherwise lack a charitable character. Further, examination of whether religious expenditure exceeded the statutory threshold is an assessment-stage exercise and cannot, without proper analysis of the actual activities and financial records, justify rejection of approval.

Conclusion: Approval under section 80G could not be denied on the stated grounds; the assessee was entitled to grant of approval.

Issues: (i) Whether profit on undisclosed or estimated sales and receipts could be assessed at 60%; (ii) Whether the addition based on Annexure A-22 was sustainable in the assessee's hands; (iii) Whether disallowance for non-deduction of tax on standard software purchase was sustainable; (iv) Whether deletion of the protective addition relating to entries belonging to other entities was justified; (v) Whether an addition for alleged excess stock could rest solely on a stock statement submitted to a bank; (vi) Whether a loose and uncorroborated notation could support an addition for alleged investment in a plot; (vii) Whether the addition for alleged salon-renovation expenditure required verification against earlier-year records; (viii) Whether a document estimating election expenses could support an addition for unexplained expenditure; (ix) Whether credits in capital, current and personal accounts required determination on peak basis with telescoping; (x) Whether Section 115BBE of the Income-tax Act, 1961 applied to income of financial year 2016-17; (xi) Whether an addition for a bank loan credit could be made under Section 68 after rejection of the books of account.

Issue (i): Whether profit on undisclosed or estimated sales and receipts could be assessed at 60%.

Analysis: The undisclosed receipts for the earlier year stood reconciled after removal of duplicate entries. No comparable material supported a 60% profit rate, whereas the regular audited results reflected a profit rate of about 8.5%. Estimation after rejection of accounts must be fair and founded on past results or comparable business circumstances. The same approach applied to the estimated turnover for the subsequent year.

Conclusion: The 60% profit rate was reduced to 12% on the relevant undisclosed or estimated sales and receipts, in favour of the assessee.

Issue (ii): Whether the addition based on Annexure A-22 was sustainable in the assessee's hands.

Analysis: The entries in Annexure A-22 corresponded with the business records, bank entries and regular accounts of the assessee's husband and his proprietorship concerns. The Revenue had accepted the annexure as relating to him in the subsequent assessment year. The presumption under Section 292C of the Income-tax Act, 1961 is rebuttable; the evidence shifted the onus to the Revenue, which did not establish that the entries represented the assessee's income. Further, the document could not be selectively relied upon for receipts while ignoring its corresponding outgoings.

Conclusion: The addition based on Annexure A-22 was deleted as unsustainable in the assessee's hands, in favour of the assessee.

Issue (iii): Whether disallowance for non-deduction of tax on standard software purchase was sustainable.

Analysis: No material established that the payment was for technical services, royalty, customised software development, or transfer of copyright rights within Section 194J of the Income-tax Act, 1961. The software was standard retail software acquired for internal business use and constituted purchase of a copyrighted article as goods.

Conclusion: No tax-deduction obligation arose on the software purchase, and the related disallowance was deleted, in favour of the assessee.

Issue (iv): Whether deletion of the protective addition relating to entries belonging to other entities was justified.

Analysis: A protective assessment cannot remain unattached to a substantive assessment. The impugned entries pertained to other identified entities, and no basis was shown for retaining a protective addition in the assessee's case.

Conclusion: Deletion of the protective addition was upheld, against the Revenue.

Issue (v): Whether an addition for alleged excess stock could rest solely on a stock statement submitted to a bank.

Analysis: The bank stock statement was an estimated statement for credit purposes, without item-wise quantitative details or rates. It was not supported by physical verification by the bank or by excess stock found during the survey. A bank statement alone, without independent corroboration that the stated stock actually existed, could not establish unexplained investment.

Conclusion: The addition for alleged excess stock was deleted, in favour of the assessee.

Issue (vi): Whether a loose and uncorroborated notation could support an addition for alleged investment in a plot.

Analysis: The impounded notation did not identify the property, seller, date, location, unit of the figure, payment, or any other transactional particulars. No agreement, registered instrument, revenue-record enquiry, third-party confirmation, or other corroboration supported the alleged investment.

Conclusion: The loose notation was insufficient evidence of an investment, and the plot-related addition was deleted, in favour of the assessee.

Issue (vii): Whether the addition for alleged salon-renovation expenditure required verification against earlier-year records.

Analysis: The impounded sheet was unsigned, undated, comprised rounded figures, and did not identify the renovated premises. The assessee's explanation that the renovation had been incurred and recorded in financial year 2013-14 substantially corresponded with fixed-asset additions disclosed in the earlier accounts. Verification of those earlier-year assessment records and audit report was required.

Conclusion: The renovation addition was remanded for limited verification; it shall be deleted if the investment is found recorded and disclosed in the financial year 2013-14 records.

Issue (viii): Whether a document estimating election expenses could support an addition for unexplained expenditure.

Analysis: The impounded document was an estimate of proposed election expenditure, and there was no evidence that the assessee contested an election or actually incurred the stated expenditure. No vouchers, payees, recipient verification, or independent evidence linked the notation to an actual transaction. A proposal or estimate lacking transactional corroboration cannot establish expenditure under Section 69C of the Income-tax Act, 1961.

Conclusion: The addition for alleged election expenditure was deleted, in favour of the assessee.

Issue (ix): Whether credits in capital, current and personal accounts required determination on peak basis with telescoping.

Analysis: The addition had been made on aggregate credit entries without considering corresponding debits, withdrawals and transfers. The claim for peak-credit computation and telescoping of estimated business income against the cash accretions required reconciliation and fresh examination.

Conclusion: The matter was remanded for fresh determination after considering peak credit and telescoping, in favour of the assessee to that extent.

Issue (x): Whether Section 115BBE of the Income-tax Act, 1961 applied to income of financial year 2016-17.

Analysis: The enhanced regime under Section 115BBE of the Income-tax Act, 1961 was held inapplicable to income pertaining to financial year 2016-17.

Conclusion: Section 115BBE of the Income-tax Act, 1961 does not apply to the income of financial year 2016-17, in favour of the assessee.

Issue (xi): Whether an addition for a bank loan credit could be made under Section 68 after rejection of the books of account.

Analysis: The disputed loan credit formed part of the same books that had been rejected under Section 145(3) of the Income-tax Act, 1961 for estimating business income. Other loan tranches from the same creditor through the same banking channel had been accepted. Once the books were rejected in their entirety, an entry in those books could not independently sustain an addition under Section 68 without separate reliable evidence.

Conclusion: The addition for the disputed loan credit was deleted, in favour of the assessee.

Final Conclusion: Income is to be recomputed using the reduced profit rate, with the Annexure A-22, software, stock, plot, election-expenditure and loan-credit additions excluded; the renovation and account-credit matters require limited fresh verification in accordance with the stated directions.

Ratio Decidendi: Income estimated after rejection of books must rest on a fair profit rate supported by past results or comparable material; rebutted presumptions and uncorroborated or selectively read impounded documents cannot sustain additions.