1994 (10) TMI 34

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....he three cases arise out of a common order of the Appellate Tribunal. The assessment year concerned is 1978-79. The first of the questions on which reference is sought relates to the addition made in respect of the alleged bogus purchase of raw cashew of 50,469 pounds. According to the Department, the addition should have been of the order of Rs. 7,48,377 at the rate of Rs. 15.77 per pound of cash....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... two of the four reasons which had been urged before the Commissioner (Appeals) for deleting the addition under this head had been accepted by the Commissioner and acceptance of those grounds has not been challenged in the appeal before the Tribunal by the Department. The Tribunal found that there was a practice of making local purchases from persons who were described as unauthorised dealers. Thi....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....dismissed the appeals. We do not find any question of law arising out of this part of the Tribunal's order. The said finding, as stated earlier, is made on an appreciation of the evidence in the case and based on materials. It cannot be said that it is either perverse or unreasonable or unsupported by any materials. No question of law is, therefore, liable to be referred out of this part of the Tr....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....sessee the closing stock value adopted contained the element of purchase tax, it could not be said that it was the correct value of the closing stock. The Tribunal was therefore justified in directing the Income-tax Officer to look into the matter. We do not find any question of law arising out of this direction which according to us is fully justified by the contention raised in the case. The ....