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Section 145 of the Income-tax Act, 1961 - Method of accounting - Rejection of accounts - Assessment year 1986-87 - Commissioner (Appeals) deleted additions made by Assessing Officer on account of bogus purchases from seven parties as also addition in trading account besides allowing triple shift allowance on machinery etc. - Tribunal concurred with analysis and conclusions drawn by Commissioner (Appeals) on appreciation of material on record, after taking notice of fact that trading results of assessee had all along been accepted and purchases of scrap from seven parties could also be not termed as bogus for reason that in subsequent assessment year purchases from those very parties stood accepted by department to a very substantial extent - Tribunal also took notice of Revenue's contradictory stand in as much as firstly specific additions were made in assessment on account of alleged bogus purchases and then assessee's books were rejected on ground that those were not verifiable, but adjustment of bogus purchases was made while working out gross profits and that too on basis of 'sales version' in those very books though with a slight modification - Whether brief capitulation of findings of fact returned by Tribunal led to an irresistible conclusion that these were pure findings of fact giving rise to no question of law - Held, yes FACTS Following a search and seizure operation under section 132(1) and examination of the books seized, the Assessing Officer suspected that the purchase of gun metal scraps from seven parties, accounted for in its account books by the assessee, was shown by it in collusion with those parties. The Assessing Officer accordingly asked the assessee to prove the genuineness of the purchases from first two of the seven parties. The assessee responded. The Assessing Officer, however, by invoking the provisions of section 145 assessed the income at a high figure on the ground that there were bogus purchases and made addition in the trading account, apart from some other inadmissible items of expenses. On appeals, the Commissioner (Appeals) held that assessee's books of account were fully verifiable, therefore, section 145 need not have…

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