TMI Blog2007 (3) TMI 211X X X X Extracts X X X X X X X X Extracts X X X X ..... to fall within the limited purview of section 260A of the Act, which is confined to entertaining only such appeal against the order which involves a substantial question of law. Accordingly, the present appeals are, hereby, dismissed. - HON'BLE MADAN B. LOKUR AND VIDYA BHUSHAN GUPTA, JJ. For the Appellant : R.D. Jolly and Sonia Mathur, Advs For the Respondent : C.S. Aggarwal, Sr. Adv. and Prakash Kumar, Adv. JUDGMENT Vidya Bhushan Gupta, J. 1. By this common judgment, four appeals being I. T. A. Nos. 1231, 1232, 1234 and 1236/2006 filed by the Revenue are being disposed of. 2. All these appeals arise out of the consolidated order dated December 9, 2005 passed by the Income-tax Appellate Tribunal (hereinafter referred to as the Tribun ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ecorded as on a particular date in the stock register as compared to the production report were compensated for on a subsequent date; that no record was maintained for goods recorded and not recorded in the stock register; so it was unverifiable as to the number of containers manufactured on a particular day, which were defective and as to whether they were recorded in the stock register at all. The Assessing Officer also observed that the work in progress was reflected in terms of metric tonnes, whereas the containers produced were reflected in terms of number. Accordingly, the Assessing Officer made the addition of Rs. 1,74,58,165 on account of understatement in production and sale of tin containers. 4. The Commissioner of Income-tax (App ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nding of the Commissioner of Income-tax (Appeals) observing that: Before us, the learned Departmental Representative has not been able to interpret the categories and detailed findings of fact recorded by the learned Commissioner (Appeals). These findings have not been alleged to be erroneous, much less perverse. Admittedly, there is no evidence on record to show that there had been any unaccounted sales of tin containers by the assessee. Rather, the assessee had provided all the requisite details regarding its production activity. Undisputedly, the production was meticulously routed through the assessee's daily production register. The entries therein were definitely co-relatable to the entries in the stock register, enabling an easy s ..... X X X X Extracts X X X X X X X X Extracts X X X X
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