Appeal cannot be decided by CIT(A) on personal opinion without any material available on record

Smt. R. Santha Vs CIT (Madras High Court) There can be no allegation against the assessee of diversion assessee and her husband, who had established the dhall mill and that the assesee is at an advantage in obtaining finished product from her husband’s dhall mill and she will be assured of time delivery of the processed dhall and assured of quality processing and obviously at discounted rates. Furthermore, there is no endeavour made by the Tribunal to examine the specific stand of the assessee that the assessee had interest free funds. Thus, we find that CIT(A) decided the case aga...