TMI Blog2006 (4) TMI 513X X X X Extracts X X X X X X X X Extracts X X X X ..... e order of Income-tax Appellate Tribunal, Chandigarh Bench B in ITA No. 123/Chd./99 in respect of assessment year 1991-92. 2. The substantial questions of law sought to be raised are as under:- (a)Whether, on the facts and circumstances of the case, the authorities below were justified in upholding the action under section 145(2)? (b)Whether, on the facts and circumstances of the ca ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he decision of ITAT is perverse as there is no evidence that the surrender was made to cover any specific defects and, thus, should have been available for set off against addition on account of gross profit? (e)Whether, on the facts and circumstances of the case, the decision of ITAT is perverse being based on erroneous criteria and irrelevant factors and is, thus, liable to be set aside? ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cer reiterated his earlier order. On appeal, the said order was affirmed by the CIT(A) with following observations:- It is thus obvious that certain items of disallowable nature or inflated items of expenditure were being debited in the profit and loss account. Since, the present addition is an estimate addition to plug such loopholes as the rejection of the books of account has already been ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the provisions of section 145(2) was justified. We are also of the opinion that the surrender of ₹ 2 lakhs during survey would not cover against the addition on account of gross profit as the same was made against specific items detected at the time of survey under section 133A. Therefore, we do not find any force in the arguments of the assessee in respect of the surrender of ₹ 2 lak ..... X X X X Extracts X X X X X X X X Extracts X X X X
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