9911796707
TMI Blog1981 (8) TMI 104X X X X Extracts X X X X X X X X Extracts X X X X ..... urchase and sale of salt. For the asst. yr. 1977-78 the assessee declared a gross profit of Rs. 85,115 on sales of Rs. 12,46,505, which gave a gross profit rate of 6.75 per cent. The ITO observed that the rate of gross profit declared by the assessee was low as compared to the rate of 14 per cent declared by the assessee for the immediately preceding assessment year and the rate of 8 per cent to 8 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... here was a heavy rush for loading with the result that there was a steep fall in the selling price of salt at such times. In the circumstances, it was pointed out that a business of this type showed considerable variation in the rate of gross profit. Finally, it was urged that the ITO had not pointed out any comparable case for the relevant year where any other dealer had shown a higher rate of gr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the ground that there was a fall in the rate of gross profit as compared to the earlier years. 6. The ld. Deptl. Rep., on the other hand, relied on the orders of the ITO and the AAC. He also challenged the correctness of the contention by the ld. counsel for the assessee that as the ITO did not find any particular flaw in the accounts of the assessee, he was bound to accept the profit disclose ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he assessee. In the instant case, on the other hand, the AAC has admitted that the assessee-firm was maintaining a quantitative tally of its goods with the result that the purchases and sales made by the assessee were amendable to verification. In the absence of any specific discrepancy, defect or omission pointed out by the ITO in the stock account or any other account maintained by the assessee- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erred in confirming the disallowance of Rs. 2,500 out of general expenses when complete details of the expenses had been furnished before the ITO. We find that the addition has been made by the ITO in a routine manner on an adhoc basis. The ld. counsel for the assessee placed before us a copy of the details of the miscellaneous shop expenses filed by him before the ITO. Having regard to the statem ..... X X X X Extracts X X X X X X X X Extracts X X X X
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