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ITAT sustained a restricted addition of Rs. 4,65,000 to the assessee's income for A.Y. 2015-16, applying a 25% estimation rate to the net alleged unaccounted expenditure derived from the seized diary. The Tribunal held that the AO's aggregation of only positive diary balances without third-party verification led to potential overstatement; accordingly, a calibrated discount was warranted to account for duplications, negative balances, vendor confirmations produced on appeal, valuation evidence indicating lower total cost than accounted payments, and absence of AO inquiries under section 131/133(6). No separate addition was sustained for A.Y. 2016-17.
ITAT sustained a restricted addition of Rs. 4,65,000 to the assessee's income for A.Y. 2015-16, applying a 25% estimation rate to the net alleged unaccounted expenditure derived from the seized diary. The Tribunal held that the AO's aggregation of only positive diary balances without third-party verification led to potential overstatement; accordingly, a calibrated discount was warranted to account for duplications, negative balances, vendor confirmations produced on appeal, valuation evidence indicating lower total cost than accounted payments, and absence of AO inquiries under section 131/133(6). No separate addition was sustained for A.Y. 2016-17.
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