TMI Blog1979 (1) TMI 117X X X X Extracts X X X X X X X X Extracts X X X X ..... his year are Rs. 12,87,609 with the gross profit of 12 per cent as against the sales of Rs. 8,11,364 with the gross profit of 14 per cent in the earlier year. The ITO has merely mentioned that the defects pointed out in the past continued to exist during this year. As the gross profit disclosed was, according to the ITO, low the ITO made a lum sum addition of Rs. 6,000 to the book results. The AAC ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on was called for. The departmental representative, on the other hand, relied on the findings of the lower authorities. 3. Considering the past assessment history, we consider that the trading results shown by the assessee this year is fair and reasonable. Trading conditions do not remain uniform year after year and may vary. It is for the ITO to bring sufficient materials on record and deal wi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... this year. It was pointed out to us by the assessee's counsel that in the statement of facts before the AAC it was made clear that there existed quantitative records and other material evidence supporting the assessee's accounts. It was pointed out to us that while in the earlier years purchases from hawkers were not evidenced, the assessee had taken care at least to bring on record the signature ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... were living close to the place of business and that the two cars owned by the firm were being very substantially used for the purpose of business. It was, therefore, pointed out that the disallowance should be reduced. The departmental representative on the other hand, pointed out that for the asst. yr. 1974-75 the disallowance was to the same extent as in the year under appeal though the total cl ..... X X X X Extracts X X X X X X X X Extracts X X X X
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