Tribunal held  that the assessee’s brokerage firm was conducting operations from various locations on all stock exchanges. The loose sheets which contained rough notings as to some shares against the name of the assessee cannot be held to be the outstanding position of the shares in the hands of the assessee as there are no corroborating or substantive evidences brought on record by the AO. The Hon’ble Tribunal noted that the sheets are not signed by any employee of the brokerage firm and concluded that these are dumb documents consisting of rough notings about the trading transactions carried out or to be carried out by the broker. The search was conducted long back and there is no chance the assessee sold the shares of such magnitude during that period.  Tribunal  held that that the co-ordinate bench during the first round of litigation admitted the books of accounts as an additional evidence and restored the matter back to CIT(A) to decide the issues on the basis of books of accounts. The Hon’ble Tribunal also acknowledged assessee’s contention that the disclosure was made at a stage when the complete books of accounts were not available and it was not possible for the group to determine its correct income from share trading profit, dividend, and capital gain etc and the disclosure was purely on estimation basis. Relying on the co-ordinate bench’s ruling in Orion Travels Pvt. Ltd. v. ACIT (ITA No.939/M/2019) held that since the books of accounts are before the Revenue and contains all the information qua the income of the assessee by way of profit on share trading, dividend and capital gain etc and the actual income of the assessee has been assessed by Revenue based on the bank statements and other accounting records the income as offered by way of composite disclosure cannot be added to the income of the assessee. (AY. 1992-93)