2005 (3) TMI 51

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.... without assigning any reasons and without controverting findings recorded in the order of the Commissioner of Income-tax (Appeals)?" In the light of the view that the court proposes to take, the appeals are taken up for final hearing and disposal. The assessment year is 1995-96 and the relevant accounting period is the year ended on March 31, 1995. The assessee filed a return of income showing income at Rs. 30,02,420 on November 30, 1995. The Assessing Officer, for the reasons stated in his order dated March 30, 1998, disallowed a sum of Rs. 20,67,776 treating the same as excessive rebate and discount allowed to various parties, including one sister concern of the appellant, namely, M/s. Vipul Exports. The assessee carried the mat....

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....agraphs Nos. 3.7, 3.8 and 3.9, while in paragraph No. 3.10, it is stated thus: "Keeping in view the totality of the facts and circumstances of the case and after examining the basis on which the Assessing Officer allowed discount at the rate of 10 per cent, and further allowed discount at the rate of 1 per cent, i.e., Rs. 50,812 on the sales of Rs. 50,81,263, we are of the view that the Assessing Officer has taken fair and reasonable view. Looking to the amount of discount and rebates allowed to other parties, we are of the view that it will meet the ends of justice if the disallowance made by the Assessing Officer is restored. We accordingly hold that the disallowance of Rs. 20,67,776 made by the Assessing Officer was fair and reasonabl....