NEENA MAHAJAN Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) This appeal under Section 260A of the Income-tax Act, 1961 (for short ''the Act'') has been filed by the assessee against the order dated 13.8.2010, passed by the Income Tax Appellate Tribunal Amritsar Bench, Amritsar (in short ''the Tribunal'') in ITA No. 64 (Asr.) 2010, relating to the assessment year 2006-07.

(2.) The following substantial questions of law have been claimed in the appeal for determination of this Court:

(3.) The facts, in brief, necessary for adjudication as narrated in the appeal, are that the assessee is an individual and she is engaged in the business of export of sports goods. Return for the assessment year 2006-07 was filed by her on 23.10.2006 declaring her income at Rs. 46,16,718. The return was taken up for scrutiny and statutory notices under Sections 143(2) and 142(1) of the Act were issued to her. During the course of assessment proceedings, the Assessing Officer rejected the books of account of the assessee on the ground that she was not maintaining 'stock records'. According to the appellant, the Assessing Officer drew adverse inference as regards the labour expenses and on the basis thereof concluded that the assessee had inflated labour expenses and suppressed the 'Gross Profit'. The Assessing Officer thereafter estimated the G.P. rate at 14% as against 8.27% as reflected by the assessee and consequently made addition of Rs. 60,00,000. The Assessing Officer, thus, after making certain additions by order dated 31-12-2008 assessed the income of the assessee at Rs.1,10,16,720 as against the 'returned income' of Rs. 46,16,718.