9911796707
TMI Blog1978 (12) TMI 61X X X X Extracts X X X X X X X X Extracts X X X X ..... e relating to the trading addition and the other pertaining to disallowance of the part of rent for residence. For the asst. yr. 1969-70 there is only one ground relating to the trading addition. 3. Before we proceed to deal on merits with the ground relating to trading addition for both the years we would like to dispose of the ground relating to the deletion of Rs. 1,200 by the AAC relating to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... appeal before the AAC. 5. The AAC examined, for both the years, the statements filed before him by the assessee showing that the total purchases included substantial partnership of local purchases in which 6 per cent Finance Tax was already included and that in other accounts the gross profit was factually low and the explanation of the assessee should have been accepted. He noted that in the as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... It was submitted that there was full justification for the additions made by the ITO and these should not have been deleted by the AAC. The learned counsel for the assessee, on the other hand, submitted that the order of the AAC deleting these additions is a speaking order and has given the reason why the AAC accepted the evidence produced by the assessee to delete the additions. His order may, th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e provisions of s. 145 cannot be attracted. The revenue, has relied upon the case law reported at 81 ITR 609 and 84 ITR 106 to support its case. But we do not find that facts to these cases can be compared to the facts of the case of the assessee. Since the facts and circumstances of the case relied upon by the Revenue are not pari materia the ratio there of have no application here. On the other ..... X X X X Extracts X X X X X X X X Extracts X X X X
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