- (1.) This is an appeal filed by the assessee against an order of the CIT(A) sustaining the enhancement of income by Rs. 2 lacs.
(2.) The assessee is an individual having income from carrying on services of pathology, X-Ray and ultrasound tests. Receipts disclosed during the year were Rs. 15,02,675. The AO noticed a register of receipts of X-Ray tests and ultrasound tests was maintained. Receipts were issued against charges received from the patients. Opening and closing stock inventories were also available. Cash book was maintained. However, according to him, there were following discrepancies : (i) No stock register of raw material was maintained; (ii) Day-to day consumption record was not there but a statement of opening stock, purchases, closing stock and consumption was compiled as desired by the Assessing Officer (AO). The closing stock in this chart showed some variations with the closing stock as per inventory as noted in the assessment order. (iii) The last cash receipt was Sl. No. 6507, which showed that there were 6507 patients, but ultrasound films 5600 and X-Ray films 10,540 were consumed; There was no satisfactory explanation why films more than the number of patients were used; (iv) Some reports were prepared on the basis of screen display, but cash receipts were not issued in such cases; (v) Daily balances were not struck in the cash book; (vi) Separate figures of consumption of ultrasound and X-Ray films were not available.
(3.) On the basis of the above, the book results were rejected under proviso to s. 145(1) and the receipts of ultrasound receipts and X-Ray tests were estimated at the rate of Rs. 250 per film for ultrasound, Rs. 60 per film for X-Rays and Rs. 15 per film for dental X-Rays, after allowing wastage at the rate of 2.28% as per claim of the assessee. This resulted in estimate of receipts at Rs. 19,74,720 as against Rs. 10,60,045 disclosed by the assessee (for X-Rays and ultrasound tests excluding Pathology and interest). The difference of Rs. 9,14,675 was added to the assessees income as supressed receipts.;