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The HC upheld the concurrent findings of the CIT(A) and ITAT that the AO failed to establish a probative nexus between calculated consumption figures and the presumed suppressed yield; therefore the AO's addition for alleged unaccounted production and sales was arbitrary and speculative. Both appellate authorities, after objective appraisal of the evidentiary material, found no adverse material to impeach the assessee's books or to justify rejection of accounts under s.145(3). In consequence, the addition premised on assumed low yield was set aside and the Revenue's appeal dismissed, the courts treating the AO's exercise as conjectural rather than evidential.
The HC upheld the concurrent findings of the CIT(A) and ITAT that the AO failed to establish a probative nexus between calculated consumption figures and the presumed suppressed yield; therefore the AO's addition for alleged unaccounted production and sales was arbitrary and speculative. Both appellate authorities, after objective appraisal of the evidentiary material, found no adverse material to impeach the assessee's books or to justify rejection of accounts under s.145(3). In consequence, the addition premised on assumed low yield was set aside and the Revenue's appeal dismissed, the courts treating the AO's exercise as conjectural rather than evidential.
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