B. N. CHATURVEDI, J.

( 1 ) THE assessee was engaged in trading of purchase and sale of rice during the accounting period 1. 7. 1987 to 31. 3. 1989, relevant for assessment year 1989-90. The entire trading in rice was done by the assessee through M/s. Ram krishan Dass Narinder Prakash. During the said period, four major sale and purchase transactions took place. Out of these, the assessee showed profits in two transactions and loss in the remaining two. The assessing officer, in order to verify the genuineness of the transactions resulting into loss, examined persons concerned and also made further necessary enquiries. On verification, the assessing officer found that sales and purchase of rice made by M/s. Ram krishan Dass Narinder Prakash on behalf of the assessee were not genuine and represented a paper transaction only. He, therefore, disallowed the loss of rs. 86. 11 lacs.

( 2 ) AGAINST disallowance of loss of Rs. 86. 11 lacs by the assessing officer, the assessee filed an appeal before CIT (A) but without a success as the CIT (A) confirmed the addition made by the assessing officer while disallowing the loss, as aforesaid. Dissatisfied by such decision, the assessee further ap

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