2008 (3) TMI 44

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.... 1.   The revenue has filed the present appeal under Section 260A of the Income-tax Act, 1961 (hereinafter referred to as the "Act") against the order dated 23.2.2007 passed by the Income-Tax Appellate Tribunal, New Delhi Bench 'E' in ITA No.4496/Del/2004 for the assessment year 2001-2002 raising the following substantial questions of law:-"1. Whether on the facts and in the circumsta....

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.... of Rs.3,30,18,576/- on the total turnover of Rs.13,00,80,622/- giving the Gross Profit Rate (GPR) of 25.38% as against 29.5% declared in the immediate preceding assessment year. 3.   The Assessing Officer required the respondent to explain the decline in the GPR for the relevant assessment year. The explanation furnished by the respondent in this regard was found to be unsatisfactory....

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....ounts only on the ground that the appellant has not been able to keep records of raw material consumed in respect of each and every item produced by the appellant. The AO has rejected without any justification the explanation of the appellant that consumption of raw material for each of the products cannot be reconciled in the case of the appellant because the product pattern was large and items o....

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....g the trading addition of Rs.20,83,752/- made by AO after invoking the provisions of Section 145(3) of the Act as the assessee failed to file quantitative details of raw materials consumed despite being allowed an opportunity. The Tribunal while partly allowing the appeal on other issues vide order dated 23.2.2007, upheld the order of CIT(A), Karnal deleting the addition of Rs.20,83,752/- made by ....