The Tribunal held that, though the addition made by the AO was not in the nature of a trading addition, it was on account of low production of oil from oil seeds in comparison to the earlier years. The variation in the yield ratio was meager and in some cases it was less than one per cent. The difference was negligible and could be due to various factors including the quality of seed, oil content in the seeds due to climate condition for a particular season which affects the quality of crop. Hence, there is no basis for sustaining the addition and such ad hoc addition without specifying the basis was not permissible. (AY. 2012-2013)