2019 (4) TMI 47

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....knowledge that he had no jurisdiction. 2. That the ld. lower authorities were not justified in law and on facts of the case in invoking provisions of Section 145(2) and in making trading addition without any cogent reason and evidence. 3. That the ld. lower authorities grossly erred in law and on facts of the case in disallowing various expenses mere on assumption of personal element and some of them being self made vouchers. 4. The appellant prays your honour indulgence to add, alter, amend and/or withdraw any grounds of appeal on or before hearing." 2. Rival contentions have been heard and record perused. 3. The facts in brief are that the assessee is engaged in manufacturing of cotton cloths. During the course of scrutiny assessm....

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....eding years. The ld AR also drawn our attention to the G.P. rate disclosed by the assessee during the year under consideration as well as the G.P. rate of the earlier two years which as under: Asstt. Year Sale Gross Profit G.P. rate 2012-13 331647410 17849130 3.18% 2013-14 456508440 23995201 5.26% 2014-15 518619995 27747902 5.35% He further submitted that in earlier year, security assessments were completed wherein results shown by the assessee was accepted. As per the ld AR, the G.P. shown during the year at 5.35% is much better than the G.P. shown in the earlier year which is 3.18% for the A.T. 2012-14 and 5.26% for the A.Y. 2013-14. Accordingly, it was prayed that no trading addition was warranted merely by rejecting the....