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1987 (5) TMI 7

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..... the following question of law for the decision of this court: "Whether, on the facts and in the circumstances of the case, the Tribunal was right in rejecting the accounts ?" The relevant assessment year is 1964-65. The assessee is a manufacturer of tiles. The Income-tax Officer noticed a huge difference between the stocks of tiles as per the accounts of the assessee and that supplied by the .....

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..... ent to reject the accounts unless there is material to corroborate the book figures as the correct figures. The plea of the assessee that if the capacity of the factory and the quantum of the current consumed and wages paid are taken into account, he could not have produced more than what is accounted for was rejected. The Tribunal took the view that there is no acceptable data to show that a cert .....

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..... e Tribunal finally found that there is absolutely no corroborating or other circumstance to show that the accounts of the assessee are reliable and the figures supplied to the bank are inflated. On these findings, the account books were rejected. Whether the accounts are correct or reliable or genuine is a pure question of fact. The said finding is not liable to attack for want of sufficient mater .....

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..... nce of such plea and proof, the conclusion of the Tribunal, rejecting the accounts on the basis of facts found, which have not been assailed, is a pure question of fact and is not open to any challenge. We hold that the Appellate Tribunal was justified in rejecting the accounts. We answer the question referred to this court in the affirmative and against the assessee and in favour of the Departmen .....

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