9911796707
TMI Blog1994 (12) TMI 339X X X X Extracts X X X X X X X X Extracts X X X X ..... questions of fact, within the limited powers, we will have to consider whether there should be interference in the matter of these questions. 2. The assessment year is 1974-75, ending on 31st March, 1974. The questions referred are as follows : 1. Whether, on the facts and in the circumstances of the case, the Tribunal is justified and had materials or basis for holding that the figure of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... showed the said income as on 31st May, 1973, to be ₹ 4,606. The ITO adopted this figure. This figure also was endorsed by the appellate authority; and (2) similarly, again in the course of search when certain books were seized, in one of them recording the transaction of Punalur head office, especially at folio 350, showing anamat varavu referred to various debit and credit entries in rega ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the books that were produced before the ITO. The Tribunal has observed that the possibility that the figure would represent profits for some other period which may be more than 12 months. Taking into consideration the above reasoning, together with the fact that already an amount of ₹ 1,191 is accepted by the officer, leaving a difference of little more than ₹ 3,000 in regard to these ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al in question has been described by the Tribunal also shows that the material would not inspire any confidence for acceptance and it is only after acceptance of the material that the ultimate amount which comes as a result of its peak could be acted upon. Additionally it cannot be lost sight of that. In such situation the ITOs have powers of taking resort to the best judgment, instead of acting u ..... X X X X Extracts X X X X X X X X Extracts X X X X
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