TMI Blog2013 (2) TMI 45X X X X Extracts X X X X X X X X Extracts X X X X ..... in the sales tax assessment, the assessee had disclosed the purchases for the relevant assessment year to the extent of Rs. 3,12,817/- and for the previous years it was disclosed at Rs. 12,32,997/-. Thus, no adverse inference can be drawn that the assessee had made purchases worth Rs. 12,32,997/- during the assessment year in question, which finding has been upheld by the Tribunal. The findings r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... order of the Tribunal: - "1. Whether on the facts and circumstances of the case, the Tribunal is justified in law in not taking into consideration an important fact that the assessee did not file its return of income for A/Y-2003-04 voluntarily but filed the same in response to notice issued u/s 148 otherwise the purchases made of Gold ornaments for Rs. 12,32,996/- and purchase of Silver orname ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e, purchase of gold ornaments amounting to Rs. 12,32,996/- and silver ornaments amounting to Rs. 3,12,817/- were not disclosed. Notice u/s 148 was issued and pursuant thereto, the return was filed. However, an addition of Rs. 12,32,996/- towards purchase of gold ornaments and Rs. 3,12,817/- towards purchase of silver ornaments, was made. The assessment was completed on an income of Rs. 15,45,813/- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... see had made purchases worth Rs. 12,32,997/- during the assessment year in question, which finding has been upheld by the Tribunal. The findings recorded by the Commissioner of Income Tax (Appeals), Allahabad as upheld by the Tribunal, are based on appreciation of evidence and material on record and do not suffer from any legal infirmity. The order of the Tribunal does not give rise to any substan ..... X X X X Extracts X X X X X X X X Extracts X X X X
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