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1994 (4) TMI 22

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....manufacture and sale of jewellery in the name and style of Yousuf Fazlehusain Zaveri in the year 1957. On July 28, 1976, Yousuf admitted his major son to the business as, a partner and petitioner No. 1 partnership firm was registered under the Indian Partnership Act. The firm is also registered with the income-tax authorities under the Income-tax Act, 1961. The previous year of the firm for the pu....

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....he firm. The order further recites that the business of the firm was subject to supervision of the Central Excise authorities and consequently its book results had therefore to be accepted. The assessment orders under section 143(3) of the Income-tax Act in respect of the assessment years 1978-79 to 1982-83 were completed and assessment orders were passed on October 2, 1979, January 21. 1980, Jan....

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....sworn on April 20, 1994. To the return, an exhibit is annexed setting out the reasons furnished by the Income-tax Officer before exercising jurisdiction to serve notices upon the petitioners. A perusal of the annexure indicates that during assessment proceedings for the assessment year 1983-84, the officer noticed that the assessee had valued the closing stock of gold as on Diwali, 1982, and the v....

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....me of concluding the assessment for the relevant years. Learned counsel urged and, in our judgment, with considerable merit, that the assessment orders leave no manner of doubt that the Income-tax Officer was satisfied after scrutiny of the books of account and the gold account, that complete quantitative details were made available and the book results had to be accepted. The averments made by th....