TaxTMI 
TaxTMI 
1991 (4) TMI 88
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....n writing before the Income-tax Officer to the addition of Rs. 10,000 ? " The assessee is a registered firm which deals in bardan, sutali, etc. The Income-tax Officer, during the assessment proceedings, found that the sales were not supported by a quantitative tally and no day-to-day quantity stock account was being maintained. Consequently, he did not accept the book results. He also noticed that, from December 1, 1967, to December 29, 1967, no purchases had been made by the assessee, but the sales have been shown at Rs. 40,455. He worked out the cost of the sales of the goods at Rs. 37,947 and presumed that there were sales without stocks to the tune of Rs. 10,287. He was of the view that this amount was introduced by the assessee as its....
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....the matter for the first time, instead of adopting the circuitous path of calling for a remand report." In this view of the matter, the Appellate Tribunal rejected the contention of the assessee regarding the justifiability of the addition of Rs. 10,000. On the merits of the case, the Appellate Tribunal found that the assessee had possessed sufficient opening stock in the manufacturing account and in the "kaltan vypar account". It noticed that the "kaltan vypar account" did not reflect the position that the goods were in fact transferred to the manufacturing account. The Tribunal, therefore, took the view that the absence of any entries, coupled with the absence of any evidence in the subsidiary registers maintained by the assessee to indi....
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....sed to record purchases and sales of kantan bales. Sometimes, whenever needed, the kantan in stock in the latter account was used for manufacture of bags, but there was no special entry passed for the purchase. This was so done, because, according to the assessee, any transfer from one account to another would be reflected when actual stocks were taken. The factual position was supported by the sworn affidavit of the chartered accountant of the assessee wherein he gave the details of the manner in which the assessee's accounts were maintained. By its order dated September 11, 1975, the Tribunal accepted the contents of the affidavit of the chartered accountant of the assessee overruling the contention of the Department that it was always e....