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8.3 Further, the second is a loose paper found during the search from the premises
of the appellant. The same was inventorized as Page No. 14 of Annexure A-5.
In this regard, the appellant submitted that the above loose paper only contained
scribbling and that it was a dumb document without any particulars or
identification. The AO did not accept this explanation and he treated the figure of
Rs 59.951/- as unaccounted purchase and with reference to section 40A(3) made
addition thereof. During the appeal, the appellant reiterated this stand that the
above loose paper is just a dumb document without any specific particulars and
the contents thereof were just scribbling.
8.4 Further, the third is a page extracted from the mobile of the appellant. The
same was inventorized as Page No. 5 of the digital data of the appellant's mobile
In this regard, the appellant initially submitted that the above is only a loose paper
containing some rough scribbling by the parties who visited his premises for price
verification The AO did not accept this explanation and he made addition of
Rs.3.94,000/- as undisclosed sale and Rs. 3,93,900/- as unaccounted purchases.
During the appeal, the appellant reiterated his stand that the above loose paper is
a scribbling. The appellant further submitted that when the AO already taxed the
total amount of Rs 3,94,000/- as unrecorded sales, he ought not to have taxed
Rs.3,93,900/- as unaccounted purchases separately
8.4.1 I have duly considered the above. The above page extracted from the mobile
of the appellant has already been considered by me while deciding ground no. 3 of
the appellant hereinbefore. I have rejected the argument of the appellant that the
above paper contain only scribbling and I have already upheld the AO's action of
treating the amount of Rs.3,94,000/- as undisclosed sales of the appellant in the
earlier paragraph of this appellate order. However, when the unrecorded sales
has been taken into account for making the addition, there cannot be separate
addition of unaccounted purchases corresponding to such sales as it amounts to
double addition. Since the amount of Rs.3,94,000/- is already taken into account
as unrecorded sales of the appellant, no separate addition of Rs.3,93,900/- can be
made as unaccounted purchase of the appellant. Accordingly, the AO is directed
to delete the addition of Rs.3,93,900/-.