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This Court finds it difficult to accept the submission of learned counsel for the petitioners that the question of the system of accounting was to be considered at the final stage of determination of income and not at the stage when the application of the petitioners had been rejected on such grounds.

Such contentions are not permissible as it is not a case where shifting from the mercantile system to cash system would not lead to any substantial difference in the ultimate income rather in the mercantile system of accounting the incomes would have to be shown on an accrual basis which has admittedly not been done by the petitioners. Thus, it was open to the Settlement Commission to have considered it as a failure to make full and true disclosure by the petitioners.