2007 (9) TMI 683

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.... ORDER 1. The revenue is aggrieved by an order dated 13-4-2006 passed by the Income-tax Appellate Tribunal, Delhi Bench 'F' ('Tribunal') in ITA No. 472/Delhi/2003 relevant for the assessment year 1997-98. 2. The assessee is a 100 per cent export unit dealing in garments. The assessee had claimed certain expenditure towards fabrication charges. The Assessing Officer issued ....

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....ties. 3. The Assessing Officer apparently did not take any steps to trace out the parties but added an amount of Rs. 43,15,352 paid to the fabricators as income from other sources. Feeling aggrieved, the assessee preferred an appeal which was allowed by the Commissioner of Income-tax (Appeals). A further appeal filed by the revenue was dismissed by the Tribunal and that is how the revenue is be....

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....ect of the matter and proceeded to come to an adverse conclusion merely on the basis that the assessee had not been able to produce the persons to whom the fabrication charges were said to have been paid. Considering the fact that few years had gone by, the explanation that the parties concerned may have moved out or closed down their business appears plausible. The mechanical approach of the Asse....