TaxTMI 
TaxTMI 
Remediable draw backs.
X X X X Extracts X X X X
X X X X Extracts X X X X
....of their 73rd Report (also para 1.23 of 76 Report and paras 1.54-56 of 100th Report), the Public Accounts Committee had desired that for gauging the problem of over-pitched assessments, a sample study may be made also of the orders of the appellate authorities higher than the Appellate Assistant Commissioners. such a study was carried out in respect of two I.A.Cs ranges in Delhi, for orders receiv....
X X X X Extracts X X X X
X X X X Extracts X X X X
....n regarding comparable comparable cases were not quoted. cases in support of the G.P rate applied or the trading results aimed at, should be given by the ITOs in a confidential note below the assessment order; in the Board's subsequent Circular No. 23 of 1957 dated 8-6-57, it was also desired that a Register for recording reasonable gross profits shown by various trades and industries in the area ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....o earlier out due enquiry and consideration. Circulars on the subject particularlyD.I (Inv.)'s No. 4 of 1960 dated 30th March, 1960 and the Board's instruction No. 218, dated 18-9-1970. The questions of onus, proper opportunity cross examination etc. should be carefully considered. 5. Additions on account of Where the amounts involved are small inadequate drawings for personal and sufficient just....
X X X X Extracts X X X X
X X X X Extracts X X X X
....rt judgment in the case of M/s. Durga Timber Works Vs. CIT 79 ITR 63. For cases of penalty based on Explanation should be explicitly canvassed and relied upon vide Board's Instruction No 325 F.No. 267/607/71-ITJ dated22-9-71. Secondly, although the validity of the Explanation has been upheld in Allahabad High Court Judgment in the case of Sayeed Ahmed vs. CIT 79 ITR 28 and the general principles o....