of the ld. AR that the Assessing Officer has simply estimated the income of the assessee without rejecting the books of account is a misconceived fact. The Assessing Officer has not at all estimated the income of the assessee. He has found the expenses claimed to earn income, which he has compared, with other years and other comparable cases. So, it is not, in fact, a case of rejection of books of account and making estimation of income u/s 145 of the Act. The Assessing Officer has found for a fact that the assessee-company has managed to sell its product through its sister concern, in which mostly Directors are partners. This is a very important aspect and has not at all been dealt by the ld. CIT(A). Another important aspect is regarding the huge expenditure incurred in the Rajah Island Project. Again, the ld. CIT(A) noticed from the assessment order that the Assessing Officer has nowhere mentioned that these expenses were not incurred by the assessee. He has not even mentioned about even a single item of unvouched expenditure. Without finding any defect in the voucher albeit mentioning that most of the expenses were paid in cash, he has not identified them. So to that extent, the ld. CIT(A) is correct that there is no evidence to deny any position of such expenses. Expenses can be separately disallowed if they are found to be inflated or false but with proof. In that view of the matter, when we mull over the entire records, primarily we find that simplicitor on the basis of comparison of expenses with assessee's earlier years or with other cases and without finding fault or material defect in the maintenance of bills and vouchers, which is the case, the Assessing Officer can not make lump sum addition. Hence, we are in agreement with the result arrived at by the ld. CIT(A) and uphold the impugned deletion.
