Assessee, a manufacturer of re-rolled steel products, faced search and seizure, and assessment was completed under section 153A read with section 143(3). Assessing Officer alleged unaccounted production and sales in SMS Division by comparing declared yield of 82.42 per cent with estimated yield of 89 per cent based on earlier search-period assessments for assessment years 2006-07 to 2012-13, and made an addition of about Rs. 19.09 crores. Assessing Officer rejected the books on the ground that low yield was not justified and GP/NP was not satisfactorily explained. Commissioner (Appeals) and Tribunal deleted the addition, holding that no defects in books or records were found and mere variation in yield or GP/NP did not justify rejection of books or estimation. High Court held that, where concurrent findings of the Commissioner (Appeals) and Tribunal recorded complete absence of any adverse or incriminating material and held that the addition was based on conjecture, such findings being pure findings of fact not shown to be perverse warranted no interference. SLP of revenue dismissed. (AY. 2013-14)