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Issues involved:
The issue in this case revolves around the rejection of the accounts by the Income-tax Appellate Tribunal, Cochin Bench, concerning the huge difference between the stocks of tiles as per the assessee's accounts and those supplied to the bank for overdraft purposes. Summary: The relevant assessment year is 1964-65, where the assessee, a manufacturer of tiles, faced discrepancies in stock figures between their accounts and those provided to the bank for overdraft purposes. The Income-tax Officer rejected the assessee's explanation, adding a sum to the trading account. The Appellate Assistant Commissioner sustained half of the addition, while the Tribunal found the accounted figures in the stock book unreliable due to contradictory figures provided by the assessee. The Tribunal concluded that there was insufficient material to corroborate the book figures as correct, rejecting the accounts and allowing a partial appeal with an addition of Rs. 18,000. Upon hearing both parties, the High Court upheld the Tribunal's decision to reject the accounts, emphasizing that the reliability of accounts is a factual matter. The Court cited precedent to support the Tribunal's findings, noting that there was material to deem the accounts unreliable. As the assessee failed to prove the findings were unsupported or irrational, the Court affirmed the Tribunal's decision, answering the question in favor of the Department. In conclusion, the High Court affirmed the Tribunal's decision to reject the accounts, emphasizing the factual nature of the assessment and the sufficiency of material to support the rejection.
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