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The HC upheld the concurrent factual findings of the CIT(A) and ITAT that the AO's imputation of unaccounted production and consequential additions - premised on an assumed 89% yield - lacked corroborative material and constituted speculative estimation. The Court found the AO's rejection of the assessee's books and the resultant additions to be baseless, occasioned by mere conjecture, and not supported by tangible evidence capable of impeaching the accounts. Consequently, the HC affirmed deletion of the additions and dismissed the Revenue's appeal, holding the concurrent orders to be neither perverse nor contrary to the record.
The HC upheld the concurrent factual findings of the CIT(A) and ITAT that the AO's imputation of unaccounted production and consequential additions - premised on an assumed 89% yield - lacked corroborative material and constituted speculative estimation. The Court found the AO's rejection of the assessee's books and the resultant additions to be baseless, occasioned by mere conjecture, and not supported by tangible evidence capable of impeaching the accounts. Consequently, the HC affirmed deletion of the additions and dismissed the Revenue's appeal, holding the concurrent orders to be neither perverse nor contrary to the record.
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