Addition for Professional Fees- Merely based on AIR not sustainable

The facts in brief are that the Assessing Officer (hereinafter referred to as the AO) noted that the AIR information showed professional receipts of 34,49,43,172/- by the assessee which were required to be reconciled with the books of accounts. The assessee reconciled major portion of the amount but could not reconcile the amount of Rs.2,32,75,363/-. It was stated by the assessee that these receipts were not received by the assessee. However, the AO observed that since the assessee had failed to reconcile the above stated receipts, he treated the same as concealed income of the assessee and ad...