Lokeshwar Singh Panta, J. - (1.) Leave granted.
(2.) This appeal has been filed by the appellant-firm against the judgment and order dated 01.11.2004 passed by the High Court of Judicature at Allahabad in Income Tax Appeal No. 94/2004. By the impugned judgment, the High Court dismissed the appeal of the appellant in limine and affirmed the order dated 15.01.2004 of the Income Tax Appellate Tribunal, Lucknow Bench.
(3.) The facts in short are as under:- The appellant-firm (hereinafter referred to as "the appellant-assessee") is carrying on business as Commission Agent in raw hides and skins. The raw hides and skins comprises of buffalo hides, cow hides, katta and katai or goat and sheep skins. The goods are brought in the Mandi (market) by Vyaparis (traders) through trucks. These Vyaparis go to different Arhatdaars (Commission Agents) of their choice where they get the goods counted. The amount is first entered in the Bilti Register, after that bundles are prepared and each Vyapari is given his Lot Number. Sometimes, the Vyaparis requested the Arhatdaars (Commission Agents) to pay the freight charges of the trucks. The Arhatdaar opens account of each Vyapari in his Ledger Book where numbers of different types of pieces of raw hides are entered without entering the money value thereof. The Vyaparis sometimes stayed in the Mandi for 4 or 5 days to study the market themselves and then they would give instructions to Arhatdaars for selling their goods.;