1980 (8) TMI 16

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.... DHILLON J.-The assessee-firm owns a rice huller and is engaged in husking of paddy. During the course of the examination of accounts for the assessment year 1972-73, relevant to the accounting period ending on September 30, 1971, the ITO found that the assessee made purchases of bardana and new gunny bags from M/s. Mehar Singh Jaswant Singh, Kanak Mandi, Amritsar. The assessee had a running accou....

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....r. It further pointed out that the payments were genuine and the identity of the payee was not doubted. The ITO. did not agree with the explanation furnished by the assessee and is allowed the amount. The assessee went up in appeal and the AAC held that the ingredients of r. 6DD(j) of the I.T. Rules, 1962, stood fully satisfied, as it was in view of the exceptional circumstances that the assess....

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....nal for referring the above question to this court for opinion. After hearing the learned counsel for the revenue we are of the view that there is no merit in this petition. As is clear from the facts an circumstances of the case, the AAC as well as the Appellate Tribunal, after having placed reliance on the affidavit of Jaswant Singh and also, on the statement made by him before the AAC, came ....