TMI Blog1990 (1) TMI 3X X X X Extracts X X X X X X X X Extracts X X X X ..... e Act " ) : "Whether , on the facts and in the circumstances of the case, the Tribunal is justified in upholding the deletion of the other source, addition of Rs. 1,01,649, constituting the unexplained cost of material and manufacturing cost of goods supplied by the assessee to the Defence Department ? " The assessment year involved is 1973-74 for which the relevant accounting year ended on Ma ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he entire sum received from the Controller of Defence Accounts ( Navy ) being the amount of investment in the goods as " income from other sources ". The assessee went up in appeal before the Commissioner (Appeals) and the Commissioner (Appeals ) held as follows "I have considered the arguments of both the Income-tax Officer and the appellant and also the contents of the assessment order. It was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... added and which was actually added, the Income-tax Officer did not have any further jurisdiction to add an additional sum by way of concealed income in the shape of monies invested in raw materials. In the circumstances, I am of the opinion that the addition of Rs. 1,01,649 was not warranted. This addition is, therefore, directed to be deleted." Against the said order of the Commissioner (Appeal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... not recorded in the books of account. The assessee supplied the goods after incurring certain cost and after manufacturing the goods and the amount that was received from the Defence Department could not represent the net income but it was the sum received including the profit and expenditure. In this reference, the finding made by the Tribunal has not been challenged and no question of perversit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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