Judgment :- V. RAMASWAMI, J. The assessee is manufacture and dealer in gold and jewellery. For the asst. yrs. 1960-61 1961-62 he reported a taxable turnover of Rs. 9, 70, 699-34 and Rs. 11, 99, 784-16 respectively. During the asst yr. 1961-62, on 13th June, 1961, on a surprise inspection, certain account books maintained by two of the goldsmiths employed by the petitioner were recovered. They showed that during the asst. yr. 1960-61, the petitioner had entrusted 331 sovereigns to one of the goldsmiths but in the account books of the assessee, only 170 sovereigns had been accounted for. Even these, the AO considered, represented different transactions and not the 331 sovereigns which had been shown in the account books recovered, from the goldsmiths. In view of the large difference, the account books disbelieved and the AO made an addition of 2/3 rds of the turnover returned in lieu of the suppressed sales turnover. In respect of the asst. yr. 1961-62 the account books of the goldsmiths showed that they were entrusted with 61 sovereigns whereas the petitioner had accounted only for 31 sovereigns. Because of this difference, the account books for 1961-62 also were not relied on and so far as the addition towards suppressed turnover was concerned, the AO considered that an addition of 1/3rd of the turnover returned would meet the ends of justice. Accordingly he made the additions in both the years. In respect of these years, the assessee also claimed a small turnover as second sale not liable for tax. On a check of the accounts, the AO considered that the purchase and sales of gold had not been properly accounted for and that the assessee had not established that they represented second sales. Accordingly he rejected that claim of exemption on the ground of second sales. These orders were confirmed by the AAC. On a further appeal, the Tribunal also confirmed the finding that the petitioner had not established second sales of bullion and that the accounts of the petitioner were not reliable. So far as the addition was concerned, the Tribunal thought that for 1960-61, an addition of 50 per cent would meet the ends of justice but confirmed the addition so far as 1961-62 is concerned. 2. In this revision, the learned counsel for the petitioner challenges both the findings. So far as the addition was concerned, the Tribunal thought that for 1960-61, an addition of 50 per cent would meet the ends of justice but confirmed the addition so far as 1961-62 is concerned. 2. In this revision, the learned counsel for the petitioner challenges both the findings. The learned counsel was not able to substantiate that the turnover claimed by him as second sales of bullion really related to second sales. The purchase and sale account of bullion had been found to be defective and there was no possibility of determining whether this sales turnover which the petitioner claimed as second sale is really second sale at all. No material also has been placed before us to show that it related to second sales. We accordingly confirm the finding of the Tribunal. 3. So far as the rejection of the accounts is concerned, there can be doubt that the petitioner had not been maintaining proper accounts and that therefore the turnover disclosed in the accounts should not be taken as reflecting the correct state of affairs. Therefore an addition towards suppressed turnover is called for. We are also not satisfied that the addition of 50 per cent in the first year and 33 and 1/3 per cent in the second year was in any way excessive or arbitrary. As seen from the account books seized from the goldsmiths in the first assessment year, even assuming that 170 sovereigns which were accounted by petitioner were included in the 331 sovereigns given to goldsmiths, 170 sovereigns is approximately 50 per cent of 331 sovereigns entrusted. The Tribunal was therefore not far wrong in stating that 50 per cent of the turnover could have been suppressed. Similarly in the second year since the sovereigns entrusted to the worker and recovered were comparatively smaller in quantity than in the previous year, the addition of 1/3 was made by the Tribunal. In these circumstances, we are unable to interfere with the order of the Tribunal. The petitions therefore fail and they are accordingly dismissed with costs, Counsel's fee Rs. 150/- in each case.