2006 (8) TMI 166

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..... nt year 1995-96. A search was carried out in the premises of the assessee on August 9/2004. As a result of the search, some documents were recovered which led the Assessing Officer to believe that there were unaccounted sales to the extent of Rs. 19,89,807 between April 1, 2004, and August 9, 2004. On this basis, he assumed that the unaccounted sales for the entire accounting year are Rs. 55,86, .....

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..... continue even in the post-search period. Against the order of the Commissioner, the Revenue preferred an appeal which was dismissed by the Tribunal and that has led to the present appeal being filed under section 260A of the Income-tax Act, 1961. Learned counsel for the Revenue has contended that the books are liable to be rejected for the entire year and this the Assessing Officer has done an .....

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..... sing Officer in the middle of the accounting year. Merely because there were some discrepancies in the pre-search period, it cannot lead to any presumption that the discrepancies would have continued in the post-search period particularly when there was factually no evidence at all as found by both the authorities below to support such a view. In our opinion, the Revenue has not been able to mak .....

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