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2014 (4) TMI 633 - HC - Income TaxRejection of book results – Restriction of extra consumption of raw materials – To what extent the additions were necessary - Held that:- The AO as well as the appellate authorities held that the book results did not reflect the correct position - CIT(Appeals) as well as the Tribunal limited such additions - CIT(A) reduced the excess sales to 20% of the turnover and, thereafter applied GP rate of 35% taking average of the three years of GP rate of the assessee – Relying upon Commissioner of Income-tax vs. President Industries [1999 (4) TMI 8 - GUJARAT High Court] - exercise undertaken by CIT(A) and the Tribunal on the basis of evidence on record gives no rise to the substantial question of law - The exercise is primarily in the nature of appreciation of evidence and would be based on questions of facts – the contentions of the revenue cannot be accepted – Decided against Revenue.
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