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31. The total turnover recorded on the excel sheet was at Rs.45,75,503/- which the Assessing Officer treated as the income of the. appellant from E-Commerce and added Rs.45,75,503/- to the income of the appellant. On considering the facts of the case I find that the information contained in annexure A-8 (file name "01- 20 nov fnp business"), does not convey that the items mentioned therein is stock of the appellant. . The appellant is doing business 'under the name and style-of-Ferns N Petals- E- Commerce", and earning commission from her various franchisees/vendors on account of their turnover sold through internet with the assistance of various websites, advertising the product of the appellant. The ownership of this stock/products sold by the franchisees/vendors is not the stock of the appellant and the appellant earns commission only from such transactions. The information down loaded from the EXCEL file was only showing that that the said products' were sold by some franchisees/vendors through the website of the affiliates of the appellant. Therefore, the inference of the Assessing Officer that the quantity mentioned the said file is the unaccounted stock of the appellant is not only Justified but impracticable too as the appellant is doing the business in perishable items whose life is short. Further the average commission of the appellant in the business of E-Commerce is around 10% and if 10% of commission on such E-commerce transactions are -applied which found recorded on excel sheet, the ITA 1013/Del/14 and ITA 799/Del/14 A.Y. 2005-06 Mrs Meeta Gutgutia, New Delhi income of the appellant would be Rs.4,57,450/-, whereas the appellant already declared a commission income of Rs.64,99,561/- for the year under consideration. A.s per the books of. account for the period 1-20 Nov.2004, the period which is recorded on excel, I find the total commission earned by the appellant was Rs.5,55,143/-. It is also a matter of fact, that the AO did not bring any material on record to prove that the information recorded on the said excel document was the stock of the appellant. The excel document on which the AO relied while making addition did not consist the date and year of transactions and on the basis of such vague recordings, surmises and conjectures, addition cannot be sustained. Considering the circumstances and facts of the case, I am of the considered view that the AO was not justified in making such addition without any substantiating evidence. Accordingly, the addition of Rs.45,75,503/- made by the AO is deleted."