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2022 (8) TMI 965 - HC - Income TaxAddition on account of low GP in manufacturing activity as well as trading activity as compared to previous years - Assessment made invoking provisions of section 145(3) - HELD THAT:- The concurrent findings were recorded by the Appellate Authority as well as the Income Tax Appellate Tribunal in holding that the invocation of section 145(3) of the Act and the consequential addition in respect of gross profit by the Assessing Officer was not proper. The findings arrived at were based on the material before the Appellate Authority in the appeal proceedings. The material was appreciated and therefrom the Commissioner of Income Tax (Appeals) could justify fall in the gross profit. The addition was accordingly directed to be deleted by the Appellate Authority and was confirmed by the Tribunal. The finding recorded based on appreciation of materials and documentary evidence are in the realm of finding of fact. No substantial question of law.
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