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TMI Blog2010 (12) TMI 790X X X X Extracts X X X X X X X X Extracts X X X X ..... being not reliable, assessment had to be made on estimation - Decided against the assessee for want of evidence - 260 of 2004 - - - Dated:- 13-12-2010 - MR.JUSTICE ADARSH KUMAR GOEL, MR.JUSTICE AJAY KUMAR MITTAL, JJ. Mr. Pankaj Jain, Advocate for the appellant. Mr. Tejinder K. Joshi, Advocate for the respondent. ADARSH KUMAR GOEL, J ( Oral) . This appeal has been preferr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... M/s Partap Bhangu Solvex (P) Ltd., village Pasiana, a diary showing unaccounted purchases from various concerns, including the assessee was seized. On being confronted with the said material, the assessee surrendered unaccounted income of Rs. 4 Lacs. During the assessment the assessing officer made additions to the declared income holding that the assessee had under-billed transactions and its bo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e case of ITO V Sachdeva Traders, Rajpura in ITA No.32/Chandi/99 for assessment year 1995-96 which was heard on 4.4.03 and decided on 6.4.03. We find that the same ld. CIT(A) has upheld the addition by applying sale rate of Rs.330 per qtl. by referring to the cases of Sunil Traders, Rajpura, S.K.Traders and Shakti Traders. We have already upheld the order of ld. CIT(A) in applying a rate of Rs.330 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ual sale price was found to be higher which rate was also adopted in another case mentioned therein. The issue is in the realm of appreciation of evidence. The entry and the books of account of the assessee being not reliable, assessment had to be made on estimation. In absence of perversity, the finding recorded by the Tribunal has to be upheld. In view of the aforesaid, question raised is an ..... X X X X Extracts X X X X X X X X Extracts X X X X
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