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1989 (7) TMI 144

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..... tial relief granted in place of full relief prayed for and the Revenue praying that no relief should have been granted. 2. The first common ground is in respect of lumpsum addition because of low percentage of G.P. The assessee is a wholesale dealer in tea. It deals in tea on chest to chest basis and its entire sales is to the traders in the Tea Market. The AO found that there was fall in pe .....

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..... and, therefore, there must be some defects. Therefore, he gave partial relief. 3. At the time of hearing before us, the learned counsel for the assessee brought to our notice various percentage gross profit rates shown and accepted in past as well as future years. It was further submitted that there was no change in system of accounting and all along the rates of G.P. were accepted. The assess .....

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..... were not reliable or the purchases were inflated. On the contrary otherwise all the date given by the assessee are accepted and addition is resorted merely because the assessee did not submit quantity details in kilograms as asked for by the AO. In our opinion, there was no justification for asking such details such had no bearing on the proceedings initiated. We find that the assessee has been sh .....

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..... sustain any amount of disallowance. We, therefore, delete the same. It appears nobody has made any attempt to verify or vouch the expenses as claimed. Without such exercise, no disallowance can be resorted to. 5. The last ground in assessee's appeal is against charge of interest of Rs. 2,119 under s. 215 of the Act. This is merely consequential and, therefore, the same shall stand modified. .....

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