SUBODHCHANDRA & CO. Vs. INCOME TAX OFFICER

JUDGEMENT

(1.) ASSESSEE has challenged judgment of the Income Tax Appellate Tribunal, Ahmedabad {"Tribunal" for short} dated 7th August 2000. Tax Appeal was admitted for consideration of following substantial questions of law :

(2.) IN Question No. 1 referred to above, though the figure is Rs. 21,31,418/=, counsel for both the sides pointed out that the correct figure is Rs. 28,31,418/=. We would, therefore, refer to such correct figure in consideration of the said question.

(3.) THE Assessing Officer painstakingly recorded the discrepancies, traced the manufacturing process and the export procedure and concluded that,"...Thus, the scrutiny of all these facts and figures shows that the purity of 22 Carat recorded in the books of account actually mean 0.917 fineness. Thus, a gold mass which is described as 0.917 fineness actually means that it contains impurity to the extent of 0.083 per 1000. This proves that the quantity of alloy mixed in the particular gold mass is only 0.083 per 1000. Thus, the basic fact is proved that the purity of the ornaments which have been exported are not higher than what has been shown by the assessee in the export voucher. What the assessee has termed 22 carat in the books of account really means gold of 0.917 purity in the export voucher."