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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/-.