Undisclosed income addition by extrapolation of documents is unsustainable

A. Sivashankar Vs DCIT (ITAT Chennai) In our considered view, the estimation made by the AO towards undisclosed income of under reporting of sales Revenue from sale of plots, is purely a guess work, which is based on the suspicion and surmises, but not based on any material evidences. Facts- The only issue that came up for our consideration from Revenue appeals for all the three AYs is estimated income from sale of plots by extrapolation of income detected during the course of search to remaining period. During the course of search, in the case of the assessee, a document in the form of sale a...