TMI Blog2015 (8) TMI 660X X X X Extracts X X X X X X X X Extracts X X X X ..... This is an appeal against the order of the Income Tax Appellate Tribunal dated 21.05.2013 deleting the addition of about Rs. 15,43,000/- in respect of the block period 01.04.1985 to 23.11.1995. 2. According to the appellant, the following substantial questions of law arise in this appeal:- (i) Whether in the facts and circumstances of the case, the order passed by the Hon'ble ITAT is perverse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ,920/- aggregating to Rs. 1,36,710/-. The books of account, however, recorded the amounts in respect of these bills as Rs. 3600/- and Rs. 7200/-, respectively. The total billed amount for the relevant date, namely, 14.02.1994 was Rs. 2,52,774/-. The Assessing Officer, therefore, proceeded on the basis that receipts to the extent of 54% were kept out of the books. On the basis of these two bills, h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... any amount from the assessee against the said bills and that they had not made any payment in respect thereof. It was found that this evidence had not been controverted by bringing any cogent material on record. It was observed that there were several transactions and that if the assessee had been indulging in the alleged practice, there would have been more such bills. In view thereof, the Assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the books of account. More important is the fact that the Assessing Officer did not doubt the GP rate of 7.4% declared by the assessee/respondent. The books of account were also subject to verification by the Excise Department which did not find any discrepancy. It is not as if the Tribunal did not take into consideration the fact that the books of account had been rejected and that the correctne ..... X X X X Extracts X X X X X X X X Extracts X X X X
|