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TMI Blog2013 (7) TMI 810X X X X Extracts X X X X X X X X Extracts X X X X ..... ellant could be rejected in absence of any finding recorded or reasons given for lack of satisfaction of the correctness or completeness of the accounts? ii. Whether, the completeness or correctness of the books of accounts of the appellant has been doubted and disbelieved on extraneous considerations, purely on the basis of presumption and conjectures? iii. Whether, business of the appellant is being same and, the books of accounts of the appellant having been maintained similarly, the Tribunal could reject the books of accounts of the appellant for A Y 2004-05/ 2005-06 when the same Tribunal had similarly accepted the books of accounts of the appellant for A Y 2003-04?" We have heard Shri S.D. Singh, learned counsel for the appellant. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he has added Rs.18,97,371/- as per Item No.3 in the discussion made by him. The CIT (A) and the Tribunal have not considered these aspects of the matter. He has relied upon Laxmi Stores v. Commissioner of Sales Tax, U.P., 1979 (43) STC 167 in which it was held that the low profit without there being any defect in account books is not sufficient ground for rejection of books of accounts. We have examined the order of the A.O. and find that it was not on the low profit alone that he rejected the books of account. He has given reasons for rejection of the books of account of which first five reasons are relevant and are quoted as follows:- "1. The Raw material used is KATEE which is used both for manufacturing carpet and Druggets. But record ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Income Tax Authorities. It is difficult to accept, as it was observed by the A.O. that the appellant is not maintaining accounts for providing different types of raw material to the weavers of which the price ranges from Rs.65/- to Rs.125/-. Further we find that the assessee could not explain as to why the rate of purchase varied and the correlation between the consumption and production. The Income Tax Authorities have not rejected the books of accounts only on the ground of reduced profit rate. They have given sufficient reasons, other than the reduced profit rate, quoted as above from the order of A.O. for not accepting the books of accounts. In our view the findings recorded by the A.O. as confirmed by CIT (A) and ITAT are findings of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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