2006 (12) TMI 81

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....ether, the Appellate Tribunal's findings are borne out from the record and whether the same are not perverse, whereby the additions of Rs.3,71,000/- and Rs.7,000/- respectively were deleted." 2. To find out whether the answer of the Tribunal is perverse or not, we have to see the reasons given by the Tribunal. For ready reference the order of the Tribunal reads as under : "We have carefully ....

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.... facts needed verification and he was without assistance of as accountant, the transactions so recorded, in our view, are undoubtedly related to the personal transactions of Shri A.B. Parikh with M/s. Gujarat Fertilizers Sihore (Mukund Trust). It cannot be ruled out that Shri A.B. Parikh while entering these transactions in the diary has mistook the firm Gujarat Fertilizers, Bhavnagar instead of G....

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....t is not all true to say that Mukund Trust was just created to link up the transactions missing in the books of the assessee firm. The initial statements made by Shri A.B. Parikh on 22.9.1980 should have been immediately followed up by the Department. It took nearly four years to confront the assessee firm. What we find from the subsequent statement of Shri A.B. Parikh and the statements of the re....