1981 (12) TMI 81

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....O for short) and as confirmed by the AAC. The assessee derived income from its business in hardware goods. The total sales have been shown at Rs. 4,89,201 with G.P. of Rs. 51,968 which worked out to 10.8 per cent as against 18.66 per cent disclosed during the earlier years. It was explained before the ITO, regarding the low G.P. that there was no increase in the selling price as in the past and se....

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....n, etc., the correct G.P. shown by the assessee should be 10.8 per cent and not 11.6 per cent as argued by the assessee's ld. counsel before him. The AAC considered the decision of the Appellate Tribunal in the case of M/s Aryan Packing Service, Bombay, which is being relied on by the assessee. He noted that the ratio of the decision was not applicable to the case of the assessee. The order of the....

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....hown by the assessee during the year under appeal. The ITO was not satisfied with this explanation of the assessee. He, however, noted that the trading accounts lack quantities and therefore, there was no proper verification of the rates and consequentially the G.P. shown by the assessee was not justifiable. We find no material on record to support the above conclusion of the ITO. In fact no findi....