Order of Tribunal ignoring and nor dealing with factual findings recorded by A.O. is perverse

There are two types of cases. One in which the assessing officer carries out the exercise which is required in law and the other in which the assessing officer ‘sits back with folded hands’ till the assessee exhausts all the evidence or material in his possession and then comes forward to merely reject the same on the presumptions. The High Court held that case to be falling in the second category. In the present case the asessing officer has not sat back with folded hands but has conducted the enquiry. He has requisitioned and examined the bank accounts and found discrepancy in th...