Held that when an unaccounted expenditure and receipts are found only profit element in unaccounted business receipts and net result of unaccounted receipts and expenditure could be brought to tax. When the assessment made substantively in hands of company, protective addition in hands of director is deleted. As regards agricultural income certificate from Gram Panchayat secondary evidence. Primary Evidence of crops, income and expenses unavailable hence fifty Per Cent. treated as agricultural income and balance treated as income from other sources.Held that cash available in hands of group hence set off to be permitted. If sufficient cash available after set off and adjustments no addition is permissible. As regards depreciation, value of addition to block of asset,addition of differential depreciation is deleted. Once the addition on substantive basis representing the investment in cash had been upheld, there could not be any addition either in the hands of the company or the assessee. (AY.2009-10, 2011-12 to 2015-16)