DHANESH COTTON GINNING DAL OIL Vs. ITO

JUDGEMENT

(1.) This is an appeal filed by the assessee against the order of the learned Dy, Commissioner (Appeals), Jodhpur, for the assessment year 1993-94.

(2.) The ground No. 1 relates to the addition of Rs. 5,262 on account of low yield of rice bran.

(3.) We have heard the rival submissions and perused the relevant materials available on records. In this case, the learned assessing officer had accepted the yield of rice the main product shown at 65.4 per cent to be reasonable but took the yield of the rice bran recovered at 8.18 per cent to be lower than 8.45 per cent shown in the assessment year 1991-92, though in the assessment year 1992-93, the same was recovered at 8.16 per cent. The assessing officer should have pointed out defects in maintenance of accounts in the absence of which no addition can be made for low yield. Besides, the assessing officer should have compared the results of current year with immediate past year i.e., assessment year 1992-93. We are also of the opinion that the appellant cannot be expected to declare the results with arithmetical accuracy in comparison to the past years as there is slight decrease in comparison to past year. Therefore, the addition of Rs. 5,266 sustained by the learned Dy. Commissioner (Appeals) for low yield of rice bran is hereby deleted.