Judgment :- THANIKKACHALAM, J. The assessee is the petitioner herein. The assessee is a dealer in electrical goods. The assessment relates to the assessment year 1980-81. There was a search in the business premises of the assessee. As a result of the search operation, additions were made in the assessment for the assessment year 1980-81. The dispute in this revision is with regard to addition of Rs. 50, 000 and Rs. 3, 600 sustained by the Tribunal. These additions were sustained out of a sum of Rs. 1, 84, 068 and Rs. 3, 591 which were sustained by the Appellate Assistant Commissioner. This amount of Rs. 1, 84, 068 and Rs. 3, 591 comprises in the following items: 1. Entries in slip Nos. 20 and 21 (Rs. 57, 440 with a gross profit of Rs. 14, 360) assessed at 9 per cent on Rs. 71, 800. 2. Entries in the book mark D and E (Rs. 1, 10, 110 and Rs. 2, 158). 3. Rs. 3, 591 comprises a small item of Rs. 149 at 4 per cent; Rs. 1, 590 at 4 per cent and Rs. 1, 852 at 4 per cent. 2. In so far as Rs. 57, 440 plus Rs. 14, 360 are concerned, the departmental representative has stated that this has been included in the local purchase account of the assessee and shown as taxable purchases. The Tribunal pointed out that without discussing the merits, the Appellate Assistant Commissioner has simply dismissed the appeal filed by the assessee holding that sales were not correlated. Considering this aspect, the addition of Rs. 71, 800 was deleted by the Tribunal. 3. In so far as the estimate of Rs. 1, 10, 110 is concerned, it relates to cables. The departmental representative found that entries are available in stock book. It is also pointed out that there was some discrepancy in the quantity noted therein. There is no conclusive evidence for the same. The estimate is also not based upon any reliable data. The Tribunal was of the opinion that at best this can be considered as a defect. The assessee relied upon a decision of this Court to the effect that mere jottings in the slip cannot be taken for the purpose of assessment and contended that this addition is not sustainable. But however, this submission was not accepted by the Tribunal. The Tribunal was of the opinion that at best this can be considered as a defect. The assessee relied upon a decision of this Court to the effect that mere jottings in the slip cannot be taken for the purpose of assessment and contended that this addition is not sustainable. But however, this submission was not accepted by the Tribunal. On the contrary considering the other circumstances, the Tribunal deleted the addition of Rs. 1, 10, 110. 4. In so far as the addition of Rs. 2, 158 is concerned, it relates to 83 coils of aluminium. The departmental representative found that these were received from Indian Cable Industries called as polythene cables. Hence they cannot be treated as sales suppression. Therefore, the Tribunal deleted this sum of Rs. 2, 158 also. With regard to Rs. 1, 590 and Rs. 149, the assessee explained that the figures were noted by the labourers, but they are not verifiable. As regards Rs. 1, 852 the assessee explained that it was returned to Delhi and it cannot be treated as sales. 5. In so far as other entries in the slips and the accounts relating to stocks, the departmental representative submitted that the entries cannot be treated as purchases. It is not, however, supported by any stock book or manufacturing accounts, according to the Tribunal. The Tribunal found that by and large the entries in some of the slips which are claimed to be stocks are not easily verifiable. Therefore, the Tribunal held that to this extent, an estimate is called for and accordingly sustained an addition of Rs. 50, 000 to the taxable turnover at 9 per cent and Rs. 3, 600 at 4 per cent. 6. As against the addition of Rs. 50, 000 and Rs. 3, 600 the assessee is in revision before this Court. 7. Learned counsel appearing for the assessee submitted that when the entire addition of Rs. 1, 84, 068 and Rs. 3, 591 were deleted by the Tribunal in the earlier portion of its order, there is no ground to sustain the addition of Rs. 50, 000 and Rs. 3, 600 on the basis of defects in the account books. 7. Learned counsel appearing for the assessee submitted that when the entire addition of Rs. 1, 84, 068 and Rs. 3, 591 were deleted by the Tribunal in the earlier portion of its order, there is no ground to sustain the addition of Rs. 50, 000 and Rs. 3, 600 on the basis of defects in the account books. Learned counsel pointed out that the report filed by the departmental representative and the fact that the entries contained in the slips are found in the account books, no further addition can be made while the addition was made on the basis of the estimate. 8. We have also heard learned Additional Government Pleader who supported the order passed by the Tribunal. 9. We have seen that the sum of Rs. 50, 000 and Rs. 3, 600 were sustained out of Rs. 1, 84, 068 and Rs. 3, 591. Out of this amount, a sum of Rs. 71, 800 relating to entries in slip Nos. 20 and 21. The departmental representative observed that this item and the transaction in slip Nos. 20 and 21 have been accounted for at page No. 170 of the ledger and that the latter has been shown under taxable turnover. The Appellate Assistant Commissioner has not made any discussion with regard to this items of addition, on merits. According to the Appellate Assistant Commissioner, sales were not correlated. But this was not accepted by the Tribunal and therefore, the addition of Rs. 71, 800 was deleted. 10. The second item consists of Rs. 1, 10, 110 and Rs. 2, 158 and they relate to the entries in book mark "D" and "E". This item of estimate relates to cables. The departmental representative found that entries are available in stock book. But there is some discrepancy in the quantity noted therein. There is no conclusive evidence for the same. The estimate was also not based upon any reliable data. The Tribunal pointed out that this would be a mistake. Considering these aspects, the addition of Rs. 1, 10, 110 was also deleted by the Tribunal. 11. Third item relates to Rs. 2, 158 pertaining to 83 coils of aluminium. The departmental representative found that these were received from Indian Cable Industries called as polythene cables. The departmental representative himself pointed out that it cannot be treated as sales suppression. Therefore, a sum of Rs. 1, 10, 110 was also deleted by the Tribunal. 11. Third item relates to Rs. 2, 158 pertaining to 83 coils of aluminium. The departmental representative found that these were received from Indian Cable Industries called as polythene cables. The departmental representative himself pointed out that it cannot be treated as sales suppression. Therefore, a sum of Rs. 2, 158 was deleted by the Tribunal. So also the submissions a sum of Rs. 1, 590 and Rs. 149 said to have been noted by the labourers and Rs. 1, 852 said to have been returned to Delhi, cannot be treated as sales were accepted by the Tribunal. Under these circumstances, it remains to be seen that the amount of Rs. 1, 84, 068 and Rs. 3, 591 were deleted by the Tribunal on the basis of various explanation offered in the order. 12. With regard to accounts relating to stocks, it was found by the Tribunal that they are not supported by any stock book or manufacturing account. The Tribunal also pointed out that the entries in some of the slips which are claimed to be stocks are not easily verifiable by them. Accordingly, the Tribunal estimated and sustained an addition of Rs. 50, 000 as the taxable turnover at 9 per cent and Rs. 3, 600 at 4 per cent. But there is no discussion in the order passed by the Tribunal to show as to how these sums of Rs. 50, 000 and Rs. 3, 600 are sustained and out of which amount. As already pointed out the addition sustained by the Appellate Assistant Commissioner with regard to these items amounted to Rs. 1, 84, 068 and Rs. 3, 591. When these additions were deleted by the Tribunal on merits, in the earlier part of its order, it is not known on what basis, the addition of Rs. 50, 000 and Rs. 3, 600 were sustained. In the absence of proper explanation for making such additions, we are unable to sustain the additions made by the Tribunal. Accordingly, the addition of Rs. 50, 000 and Rs. 3, 600 made on the basis of the estimate stands deleted. 13. In the result, the revision filed by the assessee is allowed. No costs.