Held that on the date of search by allowing mark-up on tag price of 32 per cent. when the assessee had justified a mark-up of 32 per cent. on the tag price of closing stock held as on the date of search. The estimations made by the Assessing Officer on the difference in mark-up price of closing stock was purely on the basis of suspicion and surmises, without any evidence to suggest that the assessee had average mark-up of 25 per cent. on all goods. The Commissioner (Appeals) after considering relevant facts had rightly directed the Assessing Officer to allow average mark-up of 32 per cent. to arrive at the cost price of closing stock as on the date of search. (AY.2012-13)