The Tribunal has recorded a finding of fact that document titled as "Page No.17" contained monthly receipts from April 2003 to June 2006. During the survey proceedings, the appellant did not dispute the loose paper "Page No.17" but merely stated that it may be estimated figure of receipts during the period covered in "Page No.17". However, later during the course of the assessment proceedings the appellant-assessee came up with a explanation that the document "Page No.17" is as estimated income prepared by his consultant Mr. Ramesh Shetty for the purpose of obtaining loan from the bank for the purchase of equipments. However, the Tribunal did not examine the deponent of the affidavit i.e. Mr. Ramesh Shetty as no evidence was furnished regarding appointment of Mr. Ramesh Shetty as consultant nor any fees are shown to have been paid to the consultant Mr. Ramesh Shetty. The Tribunal also records the fact that during the survey proceedings there was no mention regarding the consultant having been appointed by the appellant-assessee for the purpose of obtaining loan from the bank. In view of the above facts, the Tribunal holds that the explanation offered later is clearly an after thought as also been held by the lower authorities. In fact, during the survey proceedings, the assessee in his statement recorded on 6 September 2007 has categorically stated that the discrepancy in the figures of receipts shown in the books of
