(1.) THIS appeal by the assessee-M/s Kahan Udyog relates to block period 1st April, 1985 to 16th November, 1995 and arises out of the order of the Income Tax Appellate Tribunal dated 31st December, 1999 in IT(SS) A. No. 32/Del/96. The appeal was admitted vide order dated 9th May, 2001 and the following substantial question of law was framed:-
(2.) ON 16th November, 1995 search operations under Section 132 of the Income Tax Act, 1961 (Act, for short) were conducted at business premises of Mahavir Woolen Mills, including the present appellant. Incriminating documents were found and seized. Relying upon the incriminating documents, addition of Rs.7,63,055/- was made in the block assessment order for unrecorded/unaccounted transactions under Section 69C. The said addition was reduced to Rs.6,13,000/- by the tribunal. The appellant claims that no addition is justified and same is contrary to facts and law.
(3.) IN view of the aforesaid factual position, we do not think the findings of fact recorded by the tribunal can be categorised as perverse and justify inference or reversal in this appeal under Section 260A of the Act. The question of law is accordingly answered against the appellant assessee and in favour of the Revenue. The appeal is dismissed. No order as to costs.