Assessing Officer alleged that assessee-commodity broker had done client code modifications for unusually high number of times helping clients to divert their profits to other persons and, thus, assessee had earned unaccounted income from clients  and made addition of Rs 2 crore based on the statement of Nayan Thakkar  . However, said Nayan Thakkar  subsequently retracted from his statement .  In case of Kunvarji Finance itself, Tribunal had already found that there was no material or evidence to support additions made by Assessing Officer . Tribunal deleted the addition . On appeal by revenue the court held that since addition was not based on any material other than disclosure made by NT which was retracted, no substantial question of law arose on its deletion .  Followed PCIT v. Kunvarji Finance Ltd  dt 6-10 -2015 (Guj) (HC)  .