1978 (5) TMI 44

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....on to the tune of 11,14,018 Kgs. during the year. The yield of cotton worked out to 37.6 per cent as against 40.4 per cent of the earlier year. He therefore, felt that the accounts were not complete and acceptable. Estimating an extra yield of 1 per cent he added a sum of Rs. 16,000. On appeal, the AAC deleted the addition holding that there was no basis regarding the yield as low especially since....

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....ed that nothing has been produced to show that the yield is low. The yield depends on several factors. 3. The assessee has no ginning factory of its own. It gets cotton ginned through the factory of one Jeethmal Nandlal. The assessee does not even have a godown or either premises for holding the cotton. It is pointed out that the assessee merely instructs Jeethmal Nandlal to purchase cotton acc....

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....any particular assessee's case would be the same from year to year or it would be the same in the case of different assessees in the same place. Yield of cotton depends on the quality of cotton which again depends on the place where it is grown, the time of the year when it is purchased, the extent of retention with the agriculturists or with the ginning factory etc. Without any of these details, ....