COMMISSIONER OF INCOME TAX Vs. RAMA KRISHNA JEWELLERS

JUDGEMENT

(1.) THIS common decision will dispose of the aforestated income tax appeals filed by the Revenue relating to assessment years 2000 -01 to 2004 -05 and 2006 -07. As the issues involved are similar, we are disposing of the appeals by this order, though the facts of each individual year have been noticed.

(2.) THE respondent -assessee, a partnership firm, was at the relevant time engaged in jewellery business. The assessee was subjected to search and seizure operation under Section 132 of the Income Tax Act, 1961 ('Act', for short) on 20th January, 2006. Residential premises of the partners were also searched. Assessment proceedings under Section 153A of the Act were initiated followed by issuance of notice by the Assessing Officer for filing true and correct return of total income. The assessee vide his letter dated 22nd March, 2007 stated that the returns as filed according to the following table be treated as filed in response to notice under Section 153A of the Act: -

(3.) THE first issue raised in the present appeals relates to disallowance of 50% of expenditure as declared or shown on account of 'making charges' paid to Karigars. The details of the said expenditure as declared in the respective assessment years and the ad hoc disallowance made by the Assessing Officer of 50% are as under: -