9911796707
TMI Blog2023 (10) TMI 1143X X X X Extracts X X X X X X X X Extracts X X X X ..... 2. The instant appeal (ITA No. 8531 of 2018), under Section 260A of the Income Tax Act, 1961, has been filed against the order dated 19.06.2018 (Annexure A-3) passed by the Income Tax Appellate Tribunal, Chandigarh, in ITA No. 836/CHD/2017, in respect of the assessment year 2009-10, whereby appeal filed by the respondent-assessee against the order dated 06.03.2017 passed by the Commission of Income Tax (Appeal), Karnal, has been allowed and the appeal filed by the revenue has been dismissed. 3. The respondent-assessee (Jamna Auto Industries Ltd.) is engaged in the business of manufacturing and marketing of Spring and Spring Leaves. The Assessing Officer, during the course of the assessment proceedings, made an addition of Rs. 25,60,84,65 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ls and vouchers. The CIT (Appeals) had accepted the arguments raised on behalf of the assessee that the sale of semi finished goods made during the year was well documented and there was no excess scrap at all. Hence, the appeal filed by the assessee was allowed and the Assessing Officer was directed to delete the addition. 5. Aggrieved by the said order, the Revenue filed an appeal before the Tribunal. The Tribunal examined the issue and held that no reason was given by the Assessing Officer, as to why the value of semi finished goods sold to its sister concern should not be considered in the total production of the year for the purpose of determining the percentage of scrap generated. The Assessing Officer has neither rejected books of a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... NA 2014-15 29,513 MT Nil vide assessment order u/s 143 (3) dated 30.12.2017 and also vide TPO order u.s 92CA (3) dated 12.10.2017 NA NA 7. A perusal of the above chart shows that the assessee has been selling semi-finished goods to its subsidiary entity namely M/s Jai Suspension System since the assessment year 2009-2010 till 2014-2015. The addition of Rs. 25,20,84,653/- was made by the Assessing Officer for the assessment year 2009-2010 and this was set aside by the CIT (Appeals). However, for the assessment years 2010-2011, 2011-2012, 2012-2013, 2013-2014 and 2014-2015, no addition was made qua the semi finished goods manufactured and sold outside the books of accounts. As per the above stated chart, in all the subsequent years, a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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