2022 (1) TMI 299

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....r dated 10th July, 2017: "Whether on the facts and circumstances of the case, the Income Tax Appellate Tribunal erred in affirming the conclusion of the Assessing Officer and CIT (appeals) based on materials collected during the period subsequent to the assessment period in question as each assessment year is separate?" 2. The background facts are that the assessment for the AY in question was completed by the Assessing Officer (AO) under Section 143 (3) of the Income Tax Act, 1961 ['IT Act'] during which the books of account were produced by the Appellant Assessee. The issue was regarding valuation of the closing stock since, as noted in the assessment order, while the cash book, ledger, purchase, sale, vouchers and cash memos ....

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.... able to make out any case for acceptance of its accounts by showing of it as leading to deduction of true and correct profits, so that the rejection of its accounts under section 145 merits being upheld, particularly considering that the assessee also failed to substantiate its declared results and accounts with any evidence in the survey operations on 8-10-2007, carried by the A.O. and its business premises during the course of assessment proceedings. Reference in this context is drawn to the decisions in the case of S.N. Namasivayam Chettiar v. CIT, 38 ITR 579 (SC) and Amiya Kumar Roy & Bros. v. CIT, 206 ITR 306 (Cal.). The next question, therefore, that arises under the circumstances is the reasonability of estimation of its gross profi....