2003 (4) TMI 7

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....e under section 260A of the Income-tax Act, 1961 (for short "the Act"), is directed against order, dated March 19, 2002, passed by the Income-tax Appellate Tribunal, Delhi Bench, New Delhi, in I.T.A. Nos. 1518/Del/1997 and 2611/Del/1997, pertaining to the assessment year 1993-94. The following questions have been proposed as substantial questions of law: "(a) Whether the Income-tax Appellate Tr....

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....e background facts are as follows: The respondent-assessee is engaged in the business of grinding of various spices received from one M/s. M.D.H. Pvt. Ltd., a sister concern of the assessee, on job work basis. Having the course of assessment proceedings for the relevant assessment year, the Assessing Officer noticed that the assessee had claimed grinding loss at 14.70 per cent. Considering the ....

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....d counsel for the respondent-assessee. It is strenuously urged by Ms. Bansal that the findings recorded by the Tribunal are perverse inasmuch as it has tailed to take into consideration the material brought on record in the Assessing Officer while making the aforenoted addition. It is, thus, pleaded that the impugned order involves a substantial question of law. Mr. Aggarwal, learned counsel....

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....e assessment year 1994-95, the assessee had declared grinding loss at 14.30 per cent. which was accepted by the Department as such under section 143(1) of the Act. Moreover, in respect of the assessment year 1995 96, the assessee had declared grinding loss at 17.25 per cent. which was again accepted by the Revenue while making a regular assessment under section 143(3) of the Act. The Tribunal has ....