2005 (5) TMI 235

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..... dt. 18th Oct., 2004 passed for asst. yr. 1992-93, the assessee is in appeal before us. 2. The brief facts of the case are that the assessee, at the relevant time, was engaged in the business of trading of colours and dyes. The learned AO while processing the return under s. 143(3), rejected the book result of assessee and made certain additions. The relevant addition for adjudicating this penalt .....

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..... P.M.P. According to the CIT(A), such discrepancy had taken place due to human error, otherwise there was no excess stock available with the assessee. In the opinion of the learned first appellate authority, the learned AO ought not to have concluded that assessee was indulged in activity of unaccounted purchases and sales. However, he confirmed the addition of Rs. 1.47,643 as against Rs. 3,11,582 .....

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..... indulged in unaccounted purchases and sales. The Tribunal has confirmed the addition on the ground that sales under the year was of Rs. 52,03,601 and if GP rate of 16.2 per cent disclosed in the last year is applied on these sales, then GP should come at Rs. 8.47,843. Against this, assessee has disclosed Rs. 7,56,549. According to this method, estimated profit had come at Rs. 1,31.294, whereas th .....

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