Assessee had not been filing returns of income since its income was below taxable limit.

In the other A.Y. on the basis of report of an Inspector that the assessee has been carrying on the business of sale of milk and on the basis of report of an Inspector, CIT(A) had restricted the addition to 6% of the total cash deposit. In view of the principle of consistency, Department could not be permitted to raise an issue in isolation for the immediately succeeding year for the same assessee. The CIT(A) held that the source of credit in assessee’s bank account stood explained as turnover from sale of milk for the A.Y. under consideration. In view of the provisions of Section 44AD, AO was directed to add sum of 8% of the turnover to the assessee’s income. (AY. 2011 -12)