1978 (12) TMI 61

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....the grounds are common. 2. For the asst. yr. 1968-69, there are two grounds; one relating to the trading addition and the other pertaining to disallowance of the part of rent for residence. For the asst. yr. 1969-70 there is only one ground relating to the trading addition. 3. Before we proceed to deal on merits with the ground relating to trading addition for both the years we would like to....

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....Rs. 2,500 in the Gauhati branch on lump sum basis. These additions were agitated in appeal before the AAC. 5. The AAC examined, for both the years, the statements filed before him by the assessee showing that the total purchases included substantial partnership of local purchases in which 6 per cent Finance Tax was already included and that in other accounts the gross profit was factually low a....

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.... assessee and had merely referred to it and accepted the contentions of the assessee. It was submitted that there was full justification for the additions made by the ITO and these should not have been deleted by the AAC. The learned counsel for the assessee, on the other hand, submitted that the order of the AAC deleting these additions is a speaking order and has given the reason why the AAC acc....

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....t. We agree with him that merely because day-to-day stock register is not maintained the provisions of s. 145 cannot be attracted. The revenue, has relied upon the case law reported at 81 ITR 609 and 84 ITR 106 to support its case. But we do not find that facts to these cases can be compared to the facts of the case of the assessee. Since the facts and circumstances of the case relied upon by the ....