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2006 (1) TMI 58 - HC - Income TaxAssessment to the best of AO’s judgment - Since the assessee had in its return voluntarily made mention of the two profit-making transactions which came to be accepted by the Assessing Officer, it could not turn around to question the correctness of disclosure regarding profit-making transactions in its return and that of related entries in respect thereto in its books of account simply because the Assessing Officer doubted the correctness of the two entries pertaining to the loss-making transactions and, consequently, proceeded to make the assessment to the best of his judgment. The books of account or any other material produced before the Assessing Officer by the assessee were simply meant to support the disclosure of profit or loss set out in its return and it was always open to the Assessing Officer to scrutinise such material or entries in the books of account before accepting the same for the purpose of assessment. There is, thus, no merit in the contention on behalf of the assessee that the Assessing Officer could not have disregarded the two entries pertaining to loss-making transactions while accepting the other two entries in the books of account relating to the profit-making transactions. The Tribunal was, in the circumstances, justified in repelling the contention so raised.
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