( 1 ) TAX Appeal No. 169 of 1999 and other companion appeals arise out of two judgments. Tax Appeal No. 166 of 1999 is arising on a consequential order that might be required to be passed.

( 2 ) FOR the Assessment Year 1984-85 the assessee M/s Adinath Industries was assessed under section 143 of the Income-tax Act 1961 (hereinafter referred to as the Act ). Along with its return filed on 28. 7. 1984 showing the total income at Rs. 60,814. 00, a statement showing computation of total income was filed along with copies of profit and loss account, manufacturing account, balance sheet and partners capital account. It appears that the assessing Officer issued show cause notice on 23. 1. 1987 pointing to the assessee as under:" On inquiry with the sales-tax authorities as also with the I. T. O. Junagadh ( who is having jurisdiction over Keshod), it is learnt that M/s Geeta Industries which is alleged to be the proprietary concern of one Shri Kishorechandra Hansraj at the given address at Keshod is merely a billing agent and there is no genuine seller as such. It has come to light that the S. T. Regn. No. being 67110528 dtd. 19. 11. 82 was cancelled with effect from 7. 12.