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Assessment of the same assessee for multiple years, rejection of books of account, additions made by Income-tax Officer, appeals by both assessee and Department, discrepancies in books of account, Tribunal's findings, question of law regarding acceptance of book results. Analysis: The judgment pertains to applications under section 256(2) of the Income-tax Act, 1961, involving assessments of the same assessee for different years. For the assessment year 1971-72, the Income-tax Officer initially added Rs. 18,26,000 to the profits disclosed by the assessee, later rectified to Rs. 14,00,000, which was further reduced by the Appellate Assistant Commissioner and the Tribunal. Similarly, for 1972-73 and 1974-75, additions made by the Income-tax Officer were either reduced or deleted by the higher authorities. The Department's grievance was that the Tribunal erred in reducing the additions and accepting the book results. The core issue was whether the book results of the assessee should be accepted or not, primarily a question of fact. In the assessment year 1971-72, the Tribunal found discrepancies in the books of account, leading to a specific addition. The Department argued that the Tribunal's estimate was based on the assessee's representative's statement, challenging the legal approach. However, the Court noted that for the subsequent years, the Tribunal found the books of account acceptable, indicating a potential legal question only for 1971-72. The Court analyzed the specific defects pointed out by the Income-tax Officer and the subsequent assessments by the Appellate Assistant Commissioner and the Tribunal, emphasizing the factual nature of the conclusions reached. The Court detailed the Tribunal's assessment process, highlighting the specific discrepancies identified in the books of account for each year. It noted that the Tribunal's decision was based on factual findings and specific figures available from the books, not solely on the counsel's statement. By comparing the orders for different years and the consistency in approach, the Court concluded that the Tribunal's decision did not raise any question of law. Consequently, all the applications were dismissed, emphasizing that the Tribunal's conclusions were fact-based and did not warrant legal intervention. In summary, the judgment addressed the assessments of the same assessee for multiple years, focusing on the acceptance of book results, additions made by the Income-tax Officer, and the Tribunal's findings. The Court emphasized the factual nature of the assessments, highlighting specific discrepancies in the books of account and concluding that the Tribunal's decisions were based on factual evidence rather than legal errors.
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