2007 (4) TMI 223

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....Income-tax Appellate Tribunal was justified in upholding the order of the Commissioner of Income-tax (Appeals) in cancelling the penalty imposed by the Assessing Officer under section 271(1)(c) of the Act? 2. Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was justified in law in holding that from the details of stock collected by the Department and as given by the assessee to the bank, it is possible to hold a view that many of the items so shown had no such intrinsic value? 3. Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was justified in law in holding that it is also a fact that it is a common phenomena that the asses sees show higher val....

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....assessee derives the income from the manufacture and sale of fabricated iron goods. During the course of assessment proceedings relating to the assessment year 1983-84, the Assessing Officer on an enquiry from the bank found that the stock statement submitted by the assessee was much higher than the stock statement submitted to the Income-tax Officer. On being called upon to explain the discrepancy in the stock, the assessee by its letter dated March 24, 1986, replied that there was no discrepancy in the stock, because the statement submitted to the bank on only estimated basis and not based on the books maintained by the assessee. However, at the instance of the Assessing Officer the assessee surrendered a sum of Rs. 5.50 lakhs on March 31....