TMI Blog2003 (4) TMI 82X X X X Extracts X X X X X X X X Extracts X X X X ..... section 260A of the Income-tax Act, 1961, relevant to the assessment year 1988-89 by which the impugned order of the Income-tax Appellate Tribunal dated June 18, 2001, has been challenged. Heard learned counsel for the parties. The appellant is a limited liability company carrying on the business of manufacturing and sale of steel and ingots. In the process of manufacturing the petitioner makes ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 145(1) of the Income-tax Act as was done in the past five years, although addition made in the previous years were deleted by the Tribunal in all the years except assessment year 1987-88. The account books of the assessee were disbelieved on the basis of the past prevalent practice although in the earlier years the accounts were accepted by the Commissioner of Income-tax (Appeals) and it is allege ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the appellant and no amount has been debited to the profit and loss account. Both the appellate authorities confirmed the view of the assessing authority. Aggrieved this appeal has been filed. In our opinion, the addition made by the Tribunal is wholly arbitrary. In this connection it may be mentioned that the scrap which the petitioner purchases for use in the manufacture of steel contains some ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... for which assessment is made or the income that accrues or arises or is deemed to accrue or arise in India during such year. The computation of such income is to be made in accordance with the method of accounting regularly employed by the assessee." In the same decision, the Supreme Court also observed: "Income-tax is a levy on income. No doubt, the Income-tax Act takes into account two points ..... X X X X Extracts X X X X X X X X Extracts X X X X
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