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2012 (12) TMI 524 - ITAT CHENNAIDifference in comparable sale price - Cotton Waste sold to sister concern - market value of comparable cases as against the actual sale consideration - Held that:- Nowhere in the order sheet, the assessee agreed for an estimated addition of Rs.88,06,811/- towards difference in sale price of cotton waste. Therefore, the observation of the AO that the assessee admitted for an estimated addition of towards difference in sale price of cotton waste compared to the prevailing market price is not born out from the record. CIT(A) sustained the addition holding that the concept of revenue neutral cannot be seen from the assessment year alone and it has to be seen from the subsequent years of taxation. As the CIT(A) has not given any finding on the ground raised by the assessee that there is no admission at all by the assessee for an ad-hoc estimated addition and as the AO has not provided any data collected by him to the assessee calling for its objection for making such an estimated addition, it is necessary to set aside the issue to CIT(A) for disposing of the issue afresh - in favour of assessee for statistical purposes.
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