2006 (11) TMI 114

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....rded a Samman Patra under the scheme for honouring the tax payers from the categories of business, profession and salaried people who are highest tax payers having income about the minimum level prescribed for a continuous period stated in the Scheme which was contained in the Budget Speech delivered by the Finance Minister on 1.6.1998.  The Scheme inter alia carried incentives one of which w....

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....para (4) of the aforesaid Scheme on the ground that prior approval of the Commissioner/ Chief Commissioner was not obtained before subjecting his case for scrutiny. 4. Be that as it may. The assessing officer made certain addition by applying the GP rate on the sale figures disclosed by the assessee and disallowed the loss shown by the assessee in the accounts which was substantially reduced by....

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....sessee last year though the assessee has submitted that as for this year he has cogent good grounds to support fall in the GP rate as compared to preceding year. 6. It is in the aforesaid circumstances, this appeal has been preferred by the assessee. In view of the order which we propose to pass, we have not referred to the facts relating to account position and details. The question which was ....

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....sequent years but, at the same time, it is equally true that immunity from scrutiny for a period of three years was not in absolute terms of the scheme. There being no issue raised about the observation of the safeguard envisaged before subjecting an honoured tax payer's case to scrutiny within three years subsequent thereto viz. taking prior approval of the Commissioner/Chief Commissioner, keepin....