- (1.) TWO fold submission is advanced by the counsel for the assessee. His first submission is that ad hoc trading addition at Rs. 22,00,000 is unjustifiable. The other argument advanced by the counsel for assessee is that the correct and complete details of the depositors having already been furnished in the confirmation letter before the assessing officer, there was no justification by the Tribunal in remanding the matter with regard to cash credits.
(2.) NONE of the contentions appeals us. It is not in dispute that the net profits of the assessee in the immediately preceding year, i.e., 1998 -99 was quite high in comparison to net profit rate shown by assessee for the assessment year 1999 -2000. Though the assessee produced books of account, admittedly, the assessee did not produce stock register. Sale Bills were also not furnished. In the circumstances trading addition of Rs. 22,00,000 cannot be said to be unjustified or arbitrary. In any case this addition does not give rise to any substantial question of law. As regards the second contention, suffice it to say that the order of remand is not prejudicial to the interest of assessee as the assessee shall have full opportunity to satisfy the assessing officer about the depositors from whom capital was borrowed by the assessee. It is true that in the confirmation letter furnished by the assessee, PAN/GIR numbers of the depositors have been mentioned but complete information that could have enabled the assessing officer to confirm from the concerned depositors about the deposits was lacking.
(3.) THE appeal does not give rise to any substantial question of law. It is dismissed in limine.;