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2023 (10) TMI 1143 - PUNJAB AND HARYANA HIGH COURTUnaccounted sales - 4000.806 MTs of finished goods were the product of excess scrap - For the purpose of calculating the percentage (%) of scrap generated during the year, the assessment worked out to 7.2% and not 6.8% as had been worked out by the assessee - HELD THAT:- The assessee has been selling semi-finished goods to its subsidiary entity since the assessment year 2009-2010 till 2014-2015. The additionwas made by the AO for the assessment year 2009-2010 and this was set aside by the CIT (Appeals). For the assessment years 2010-2011, 2011-2012, 2012-2013, 2013-2014 and 2014-2015, no addition was made qua the semi finished goods manufactured and sold outside the books of accounts. As per the stated chart, in all the subsequent years, assessment orders have been passed u/s 143 (3) - A perusal of the assessment orders shows that consistently the sales of semi finished goods made by the appellant to M/s Jai Suspension Systems as a sister concern have been accepted and account books to this extent have also been accepted by the Assessing Officer. Revenue has not been able to dispute the correctness of the aforesaid orders passed u/s 143 (3). After 2009- 2010, no addition has been made in the income of the appellant towards the sales of semi-finished goods to M/s Jai Suspension Systems. No substantial question of law arises
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