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TMI BlogRemediable draw backs.X X X X Extracts X X X X X X X X Extracts X X X X ..... ay that in paragraph 4.26 of their 73rd Report (also para 1.23 of 76 Report and paras 1.54-56 of 100th Report), the Public Accounts Committee had desired that for gauging the problem of over-pitched assessments, a sample study may be made also of the orders of the appellate authorities higher than the Appellate Assistant Commissioners. such a study was carried out in respect of two I.A.Cs ranges i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ults, because that information regarding comparable comparable cases were not quoted. cases in support of the G.P rate applied or the trading results aimed at, should be given by the ITOs in a confidential note below the assessment order; in the Board's subsequent Circular No. 23 of 1957 dated 8-6-57, it was also desired that a Register for recording reasonable gross profits shown by various trade ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... its with- Attention is invited to earlier out due enquiry and consideration. Circulars on the subject particularlyD.I (Inv.)'s No. 4 of 1960 dated 30th March, 1960 and the Board's instruction No. 218, dated 18-9-1970. The questions of onus, proper opportunity cross examination etc. should be carefully considered. 5. Additions on account of Where the amounts involved are small inadequate drawings ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e, mentioned in the Delhi High Court judgment in the case of M/s. Durga Timber Works Vs. CIT 79 ITR 63. For cases of penalty based on Explanation should be explicitly canvassed and relied upon vide Board's Instruction No 325 F.No. 267/607/71-ITJ dated22-9-71. Secondly, although the validity of the Explanation has been upheld in Allahabad High Court Judgment in the case of Sayeed Ahmed vs. CIT 79 I ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d, have recently furnished to the Board copies of such favourable orders from the Tribunal Benches in their charge and they are requested to circulate these orders early as indicated above. 3. The Commissioners/Additional Commissioners of Income-tax are requested to apprise the Inspecting Assistant Commissioners, Authorised Representatives and Income-tax Officers in their charge accordingly; cop ..... X X X X Extracts X X X X X X X X Extracts X X X X
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