1980 (9) TMI 120

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....ouchers in support of such payments were furnished at the time ot hearing and were verified by the ld. ITO. For that the ld. AAC is not justified in sustaining the entire addition of Rs. 10,000 under the head "Trading Account". The ld. ITO. added back the amount saying the assessee has shown sales of Rs. 2,80,386 and net profit thereon is shown at Rs. 7,884 expenses are explained with vouchers. In view of this I make a lump sum addition of Rs. 10,000 as inflation of expenses also in view of the fact that there was no withdrawal for personal expenses." When it was stated before the ld. AAC that all the expenses are verifiable from records and reliable vouchers which were produced before him, he wanted bifurcation of such expenses. The bur....

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.... of Welfare Expenses are upheld. 3. As regards ground No. 2 relating to the trading addition at Rs. 10,000, it has been made and sustained by the lower authorities, in lump sum basis and in lieu of inflation of expenses and also in view of the fact that there was no withdrawal for personal expenses. The lower authorities have not pointed out any item of expenses vis-a-vis inflation of expenses, nor any item of expenses has been pin pointedly pointed out to be not vouched the addition seemingly, has been made on lump sum on estimate and in view of no withdrawals for personal expenses by the constituents of the assessee, which to our mind does not appeal to reason. The addition-disallowance in lieu of any expenditure head has to be pin poi....

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.... that the explanation of the assessee has been brushed aside. The mere fact that the family who owned the business has had income or else has had no income could not by itself be a reason or ground for treating the amount of Rs. 17,845 as income from other source on the facts of the assessee's case. Non-with-drawals by the members of the family for personal expenses as also the absence of necessary explanation to show that the family has other source of income, could not be a ground for making and sustaining of the addition. The assessee has explained that the capital formation at Rs. 3,89,317 represented agricultural income viz; production and sale of green tea and the assessee claimed that the garden was being run without factory. The exp....