https://www.taxtmi.com/caselaws?id=792068 Arbitrary notional additions based on ad hoc percentages were held unsustainable where they lacked a reasonable factual foundation. An estimated 1% addition on investments in the balance sheet was deleted because it rested only on non-compliance with notices and not on supporting material. An estimated 12% addition on loans and advances, together with restoration of the matter to the Assessing Officer, was also set aside because the record already contained evidence and explanations, yet the authorities proceeded on surmises and presumptions. The governing principle is that additions cannot be sustained on mere notional estimation or arbitrary percentages without objective basis in the material on record. en-us Wed, 20 May 2026 00:00:00 +0530 Fri, 22 May 2026 07:06:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792068 Arbitrary notional additions based on ad hoc percentages were held unsustainable where they lacked a reasonable factual foundation. An estimated 1% addition on investments in the balance sheet was deleted because it rested only on non-compliance with notices and not on supporting material. An estimated 12% addition on loans and advances, together with restoration of the matter to the Assessing Officer, was also set aside because the record already contained evidence and explanations, yet the authorities proceeded on surmises and presumptions. The governing principle is that additions cannot be sustained on mere notional estimation or arbitrary percentages without objective basis in the material on record. Case-Laws Income Tax Wed, 20 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792068