While the books showed lower receipts, Form 26AS reflected higher amounts. In contrast, the books recorded net facility income, with income from other services disclosed separately under miscellaneous income. Ltd., where additions based solely on Form 26AS mismatches were held to be unsustainable. After considering the submissions, the Tribunal observed that the impugned addition was made purely on the basis of differences between Form 26AS and the books of account. In the absence of any evidence of unrecorded receipts or defects in the books, the addition could not be sustained.