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Issues involved: Interpretation of unaccounted sales, rejection of books of account, estimation of unaccounted sales for the entire year.
Interpretation of unaccounted sales: A search revealed unaccounted sales prompting the Assessing Officer to estimate total unaccounted sales for the year. Commissioner differentiated between pre and post-search periods, finding no evidence of unaccounted sales in the latter. Rejection of books of account: Revenue argued for rejecting books for the entire year based on search findings. Court disagreed, stating no presumption can be drawn without evidence. Estimation of unaccounted sales for the entire year: Revenue justified estimating unaccounted sales for the whole year. However, both Commissioner and Tribunal found no discrepancies in post-search period, rejecting Revenue's argument. The High Court held that without evidence of discrepancies in the post-search period, no presumption of unaccounted sales continuing throughout the year could be made. The Revenue failed to establish any substantial question of law, leading to the dismissal of the appeal filed under section 260A of the Income-tax Act, 1961.
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