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TMI Blog2011 (2) TMI 344X X X X Extracts X X X X X X X X Extracts X X X X ..... ate for the respondent. AJAY KUMAR MITTAL, J. 1. This appeal has been preferred by the revenue under Section 260A of the Income Tax Act, 1961 (in short "the Act") against the order dated 6.1.2006 passed by the Income Tax Appellate Tribunal, Amritsar Bench, Amritsar, in ITA No. 365/(ASR)/2005, relating to the assessment year 2001-02, claiming the following substantial questions of l ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... The assessment was framed on 19.3.2004 at a total income of Rs.3,91,596/-. During assessment proceedings, the Assessing Officer made various additions including an addition of Rs.20,00,000/- on account of losses disallowed claimed in trading of rice. Feeling aggrieved, the assessee filed an appeal before the Commissioner of Income Tax (Appeals) [in short "the CIT(A)"] who vide order dated 31.3.200 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r loss in the said trading. The assessee submitted an account of opening balance, purchases, sales and closing stock of these cereals without accounting for the incidental expenses. Further details of sales and purchases party wise of these commodities was also requested with evidence. The assessee submitted a list of sale and purchases of rice bill wise without mentioning the quality of Rice purc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 5. G.J.Agro Inds., Jalandhar. It is, therefore, observed that purchases of rice are not verifiable with reference to parties and also in the absence of purchase bills." 5. The CIT(A) and the Tribunal had reversed the said finding without referring to any material relating to the identity of the aforesaid sellers. The CIT(A) as well as the Tribunal had noticed that the purc ..... X X X X Extracts X X X X X X X X Extracts X X X X
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