1986 (4) TMI 83

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.... was Rs. 10,057. Similarly on the total diamond majuri commission receipts of Rs. 19,95,048 the assessee has disclosed gross profit of Rs. 67,258. The ITO, however, made a lump sum addition of Rs. 10,000 with the remarks that the assessee has not maintained complete quantity tally of diamonds. The assessee cannot prove as how he has arrived on value of closing stock. 4. In appeal, the assessee strongly argued that there is no justification in making an estimated addition of Rs. 10,000 to the trading results. In this connection, the assessee relied on the order of the CIT(A) for the asst. yr. 1979-80 wherein he had deleted addition of Rs. 5,000 made by the ITO on similar reasons. It was, therefore, urged that Rs. 10,000 should be deleted ....

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....r an estimated addition in that regard. I feel that the addition at 0.5 per cent of Rs. 20 lakhs would amount to Rs. 10,000 and the lump sum addition of 10,000 made by the ITO is, therefore, reasonable. The ground of appeal is, therefore, rejected". 5. Being aggrieved by the order of the CIT(A), the assessee has come up in appeal before the Tribunal. The ld. counsel for the assessee vehemently argued that the CIT(A) was not justified in sustaining the addition of Rs. 10,000 made by the ITO on a ground different than considered by the ITO. In this connection, he further submitted that even though full details of the majuri payments were filed before the CIT(A), as was done in respect of the asst. yr. 1979-80 wherein he did not find any de....