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mistaken belief that there is clerical error on the part of accountant hence the clerical error is income of the appellant company". Perusal of the same page again brings out it has been pleaded that "He simply believed th e S urve y Of f ic ers" Thi s is a re peated stand on re cord. Before us also it has been argued that he was not conversant with the day today running of business. These arg uments have been advance d bef ore the tax auth oritie s and come s out from a reading of the statement re corded by the Survey team. The surrender was admittedly made in the absence of legal and professional advice from his accountants etc. It is evident from record that faced with what he was convinced to be the survey team's evidence, he agreed to make a surrender is a fact staring from the face of the re cord itself. When it was conveyed to the Director that there was variation in stock found vis a vis books and receipt of unrecorded amounts from debtors alle gedly received outside books which as per argu me nts advanced before us, he understood this to be a case where some clerical errors were there on record. His naivety and ignorance is evident from the fact that he did not even question to wonder where is the money for the alleged unrecorde d recoveries or any such evidence. He admittedly was financially ignorant of the ITA-1616/CHD/2019 A.Y. 2011-12 affairs as he did not even take into consideration the fact that no cash was found. Nor did he question the fact of absence of evidence of the claim that there were unrecorded p ayme nts f rom Su nd ry deb tors. It clearly emerges that it is a case of total belief in the Survey team's version and a mistaken belief that there were some grave clerical errors. Admittedly, as per the accepted position amongst the parties itself, the books of account were not upto date, no money was found, thus on what basis the information was being conveyed that the se were payments received outside books. Similar is the position for the allegation that excess stock was found. We have seen that this was an arbitrary estimation/ approximation. Shortcomings in the calculation in weighing classifying unscientific arbitrary estimates remain unrebutted. We find in the face of the overwhelming evidence available on record the surrender made on mistaken facts and appreciation of law has no relevance. Similarly the valuation of the finished stock considering with the evidence on record again is seen to be arbitrary estimates hence, lacks cred ib ili ty is evi de nt on the face of the record itself. The responses of the Director to the specific questions raised shows that he was entirely operating on believing the version of the Survey team. The responsible per son , his Accou ntant Mr. Kamal Mehta (Q.No. 6) it is seen was apparently never ITA-1616/CHD/2019 A.Y. 2011-12 questioned. On a reading of the surrender it is seen that relatable to the surrender conclusions were presented and most questions asked were not relatable to the surrender made . The abse nce of know ledge of the Di rector and the surrender gives stre ngth to the argument raised that he was not qualified in the day to day affairs of the company. Th us, it needs no further support. Th u s, the f act that it could not be recalled that diesel expenses were being paid by cheques by the Mohali Unit is possible. No fact or evidence has been placed before us to rebut this consistent claim. Explanations have been repeatedly given that at the relevant ti me , activities were carried out in Mohali Unit and these p ayme nts booke d by the Chandigarh Unit were consequently paid by cheque by Mohali Unit. Someti me after Nove mber , 2011, it has been claimed these have been paid by the Chandigarh Unit. Th i s c l a i m h a s b e e n m a d e r i g h t f r o m t h e assessment stage (pages 10 to 11 of assessment order). It re main s u nreb utted on rec ord. Thus the f act that he was unable to recall or was not aware of hence, the responsible Accountant should ideally have been questioned remains evident. Whatever may be the case i.e. lack of recall or knowledge, the fact re mains that the evidences of their p ayme nt by cheque was readily available. Th i s argument/explanation based on supporting evidences ITA-1616/CHD/2019 A.Y. 2011-12 remains unrebutted. Similarly, allegations of unrecorded salary and wages expenses are based on no evide nce except the surrender. Responses to Q. 17 at page 92 that he agrees with the Survey te am's allegation and says "it is possible"