Held, allowing the appeal, that the amounts were received from the sole proprietorship through banking channels. In the assessment and the appellate proceedings, no discrepancies were found in the purchases or stocks of the assessee. Before the Tribunal, the assessee had submitted details of stocks as well as a ledger account with quantitative details of goods. All these documents were a part of the proceedings before the lower authorities. No question had been raised about the purchase of the goods which were duly sold by the assessee to the party in question. The addition was made entirely on the basis of the statement of the sole proprietor. That statement had not been served on the assessee. The assessee was not allowed to cross-examine the sole proprietor. The entire gross sales were duly returned by the assessee. The books of account were rejected under section 145(3) of the Act without finding any lacuna or specific discrepancy therein. The Assessing Officer had assumed that the cash deposited in the bank account of the sole proprietor belonged to the assessee. The additions had thus been made on the basis of surmises and conjectures, ignoring the evidence produced by the assessee. There was a lack of cogent evidence in respect of the addition. The assessee could not be taxed doubly in respect of the same amount which had already been declared in its return of income. The amount of sales by itself could not represent the income of the assessee who had not disclosed such sales. It was only the realisation of excess over the cost incurred that formed part of the profit included in the consideration of sales. The addition is deleted.The Tribunal also held that  without identifying any specific lacuna  rejection of books of account is unjustified.   (AY.2014-15)