Sutlej Cotton Mills Ltd. v. CIT

116 ITR 1Supreme Court of India1979#177 most cited

What is Sutlej Cotton Mills Ltd. v. CIT authority for?

A gain arising from the cancellation of a forward exchange contract entered into for the acquisition of a capital asset constitutes a capital receipt. Income-tax liability for such transactions is determined by the specific provisions of the Income Tax Act, independent of the accounting treatment in the books of account.

409

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2007 to 2026.

Also referred to as

Sutlej Cotton Mills Ltd · 116 ITR 1 · capital receipt · foreign exchange gain · forward contract · capital asset · Section 43A · income tax liability · accounting treatment · capital gains

Sections most often in play

Section 14ASection 37(1)Section 115JBSection 143(3)Section 32Section 143(2)Section 142(1)Section 250
Read the full judgment

Issues it is cited on

section 43aeligible businessbook profitssection 115jsection 115jbrevenue expendituresection 80iamercantile system of accountingamalgamationsection 37(1)section 80isection 43

Judgments citing Sutlej Cotton Mills Ltd. v. CIT

M/S Niit Ltd., New Delhi vs. DCIT, New Delhi

In the result, ITA.No.2801/Del

ITA 2801/DEL/2017[2009-10]Status: DisposedITAT Delhi01 Nov 2019AY 2009-10

Bench: Shri Bhavnesh Saini, J.M. & Shri O.P. Kant, A.M.

For Appellant: Shri Tejasvi Jain, C.A. &For Respondent: Shri Sankar Naskar, Sr. D.R
Section 143(1)

…ollowed for the same in the books of account. The assessee relied upon the decisions of 6 ITA.No.376/Del./2014 & ITA.No.2801/Del./2017 M/s. NIIT Ltd., New Delhi. the Hon’ble Supreme Court in the case of Sutlej Cotton Mills Ltd., vs. Commissioner of Income Tax 116 ITR 1 (SC) and Kedarnath Jute Mfg. Co., Ltd., vs. Commissioner of Income Tax 82 ITR 363 (SC). It was submitted that under the Income Tax Act depreciation is allowable under section 32 of the I.T. Act only to the ‘Owner’ of the asset. Lease charges paid for the use of the asset, without acquiring any ownership rights in the same, are allowable as revenue…

M/S. Niit Ltd., New Delhi vs. DCIT (Ltu), New Delhi

In the result, ITA.No.2801/Del

ITA 376/DEL/2014[2009-10]Status: DisposedITAT Delhi01 Nov 2019AY 2009-10

Bench: Shri Bhavnesh Saini, J.M. & Shri O.P. Kant, A.M.

For Appellant: Shri Tejasvi Jain, C.A. &For Respondent: Shri Sankar Naskar, Sr. D.R
Section 143(1)

…ollowed for the same in the books of account. The assessee relied upon the decisions of 6 ITA.No.376/Del./2014 & ITA.No.2801/Del./2017 M/s. NIIT Ltd., New Delhi. the Hon’ble Supreme Court in the case of Sutlej Cotton Mills Ltd., vs. Commissioner of Income Tax 116 ITR 1 (SC) and Kedarnath Jute Mfg. Co., Ltd., vs. Commissioner of Income Tax 82 ITR 363 (SC). It was submitted that under the Income Tax Act depreciation is allowable under section 32 of the I.T. Act only to the ‘Owner’ of the asset. Lease charges paid for the use of the asset, without acquiring any ownership rights in the same, are allowable as revenue…

The ACIT, - 4(1), Indore vs. M/S. Yash Technologies Pvt. Ltd., Indore

In the result appeal of the revenue is dismissed

ITA 616/IND/2018[2014-15]Status: DisposedITAT Indore31 Oct 2019AY 2014-15

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradassessment Year 2014-15 Pan : Aaacy1868M

Section 10ASection 115JSection 143(3)Section 28Section 40

…ncy transaction separately. Rather the gain in foreign currency fluctuation was outcome of business activity. 8. Ld. Counsel for the assessee placed reliance on the judgment of Hon'ble Supreme Court in the case of Sutlej Cotton Mills Ltd vs. CIT reported in 116 ITR 1 and relying on this judgment, learned CIT(A) has rightly held that this item partake the character of business income and prayed for allowing the claim. 9. Per contra Ld. Departmental Representative vehemently argued supporting the order of Ld. A.O. 10. We have heard rival contention and perused the records placed before us. Grievance of the r…

The ACIT, Circle - 1, Rajahmundry vs. The Andhra Pradesh Paper Mills Ltd., Hyderabad

In the result, appeals filed by the Revenue are partly allowed and the cross objections filed by the assessee are partly allowed

ITA 6/VIZ/2014[2009-10]Status: DisposedITAT Visakhapatnam30 Oct 2019AY 2009-10

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

For Appellant: Shri T.M. Shiv Kumar – AdvFor Respondent: Shri T.S.N. Murthy – CIT DR
Section 263Section 32

…ill depend upon the provisions of law relating thereto and not on the view which the assessee might take of his rights, nor can the existence or absence of entry in his books of account be decisive or conclusive in the matter.” Sutlez Cotton Mills Ltd. v. CIT 116 ITR 1 (SC), it was held as follows: "It is now well settled that the way in which entries are made by an assessee in his books of account is not determinative of the question whether the 'assessee has earned any' profit or suffered any loss. The assessee may, by making entries which are not-in conformity with the proper principles of accountancy, conceal…

The ACIT, Circle - 1, Rajahmundry vs. The Andhra Pradesh Paper Mills Ltd., Hyderabad

In the result, appeals filed by the Revenue are partly allowed and the cross objections filed by the assessee are partly allowed

ITA 5/VIZ/2014[2008-09]Status: DisposedITAT Visakhapatnam30 Oct 2019AY 2008-09

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

For Appellant: Shri T.M. Shiv Kumar – AdvFor Respondent: Shri T.S.N. Murthy – CIT DR
Section 263Section 32

…ill depend upon the provisions of law relating thereto and not on the view which the assessee might take of his rights, nor can the existence or absence of entry in his books of account be decisive or conclusive in the matter.” Sutlez Cotton Mills Ltd. v. CIT 116 ITR 1 (SC), it was held as follows: "It is now well settled that the way in which entries are made by an assessee in his books of account is not determinative of the question whether the 'assessee has earned any' profit or suffered any loss. The assessee may, by making entries which are not-in conformity with the proper principles of accountancy, conceal…

The ACIT, Circle - 1, Rajahmundry vs. The Andhra Pradesh Paper Mills Ltd., Hyderabad

In the result, appeals filed by the Revenue are partly allowed and the cross objections filed by the assessee are partly allowed

ITA 4/VIZ/2014[2007-08]Status: DisposedITAT Visakhapatnam30 Oct 2019AY 2007-08

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

For Appellant: Shri T.M. Shiv Kumar – AdvFor Respondent: Shri T.S.N. Murthy – CIT DR
Section 263Section 32

…ill depend upon the provisions of law relating thereto and not on the view which the assessee might take of his rights, nor can the existence or absence of entry in his books of account be decisive or conclusive in the matter.” Sutlez Cotton Mills Ltd. v. CIT 116 ITR 1 (SC), it was held as follows: "It is now well settled that the way in which entries are made by an assessee in his books of account is not determinative of the question whether the 'assessee has earned any' profit or suffered any loss. The assessee may, by making entries which are not-in conformity with the proper principles of accountancy, conceal…

Shree Digvijay Cement Co. Ltd., Sikka vs. The Assistant Commissioner of Income Tax, Circle-2, Jamnagar

In the result the appeal of the assessee is allowed

ITA 184/RJT/2011[2007-08]Status: DisposedITAT Rajkot22 Oct 2019AY 2007-08

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./I.T.A. No.184/Rjt/2011 ("नधा"रण वष" / Assessment Year : 2007-08) बनाम/ Shree Digvijay Cement Co. A.C.I.T, Ltd., Circle-2, Vs. Digvijaygram Sikka, Jamnagar. Jamnagar. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aadcs0957J (अपीलाथ" /Appellant) (""यथ" / Respondent) .. अपीलाथ" ओर से / Appellant By : Shri Vimal Desai, A.R ""यथ" क" ओर से/Respondent By : Shri Jitender Kumar, Cit.D.R सुनवाई क" तार"ख / Date Of Hearing 19/09/2019 घोषणा क" तार"ख /Date Of Pronouncement 22/10/2019 आदेश / O R D E R Per Waseem Ahmed: The Captioned Appeal Has Been Filed At The Instance Of The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals) Jamnagar [Ld. Cit(A) In Short] Dated 29/03/2011, Arising In The Matter Of Assessment Order Passed Under S. 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As "The Act") Dated 21/12/2009 Relevant To Assessment Years (A.Y.) 2007-08. A.Y. 2007-08 The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri Vimal Desai, A.RFor Respondent: Shri Jitender Kumar, CIT.D.R
Section 143(3)

…ote that the audit report cannot replace the provisions of law and the principles laid down by the Hon’ble Court’s. In this regard we find support and guidance from the judgment of Hon’ble Supreme Court in the case Sutlej Cotton Mills Ltd. Vs. CIT reported in 116 ITR 1 wherein it was held as under: “It is now well settled that the way in which entries are made by an assessee in his books of account is not determinative of the question whether the assessee has earned any profit or suffered any loss. The assessee may, by making entries which are not in conformity with the proper accountancy principles, conceal pro…

Sri Ramadas Paper Boards (P) Ltd., Hyderabad vs. DCIT, Circle-3(2), Hyderabad

In the result, appeal of the assessee is allowed

ITA 1514/HYD/2016[2012-13]Status: DisposedITAT Hyderabad09 Aug 2019AY 2012-13

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2012-13 Sri Ramadas Paper Boards (P) Vs. Dy. Commissioner Of Income- Ltd., Hyderabad. Tax, Circle – 3(2), Hyderabad. Pan – Aadcs2140M (Appellant) (Respondent)

For Appellant: Shri G.V.N. HariFor Respondent: Date of hearing
Section 143(1)Section 143(2)Section 211

…brought into Act vide Finance Act, 2002 w.e.f. 1/4/2003. Sec,43A clearly stipulates that the cost of asset would increase / decrease depending on fluctuation in foreign exchange rates. The Hon'ble Supreme Court in case of Sutlej Cotton Mills Ltd Vs CIT (1979) 116 ITR 1 (A.Y 1957-58,&1959-60) clearly held that the loss in respect of capital asset would not be allowable. The Hon'ble Court further held that whether the loss suffered by the assessee was a trading loss or not would depend on the answer" to the question, whether the loss was in respect of a trading asset or a capital asset. In the former case, it would…

DCIT, New Delhi vs. M/S. Citi Financial Cosumer Finance India Ltd., New Delhi

In the result, appeal filed by Revenue is dismissed

ITA 3118/DEL/2016[2010-11]Status: DisposedITAT Delhi29 Jul 2019AY 2010-11

Bench: Shri H.S. Sidhu & Shri Anadee Nath Misshra

For Appellant: Shri Gaurav Gupta, AdvFor Respondent: Shri S.S. Rana, CIT(DR)
Section 143(3)

…al Consumer Finance India Ltd. provisions contained in the Act [See - Kedarnath Jute Mfg. Co. Ltd. v. CIT [1971] 82ITR 363 (SC); Tuticorin Alkali Chemicals & Fertilizers Ltd. v. CIT [1997] 227ITR 172/93 Taxman 502 (SC); Sutlej Cotton Mills Ltd. v. CIT [1979] 116 ITR 1 (SC) and United Commercial Bank v. CIT [1999] 240 ITR 355/106 Taxman 601 (SC). 20. At the most, an inference can be draum that by showing this expenditure in a spread over manner in the books of account, the assessee had initially intended to make such an option. However, it abandoned the same before reaching the crucial stage, inasmuch as, in the…

Jaldeep Farms Pvt Ltd., Ahmedabad vs. The ITO, Ward-2(1)(2), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 222/AHD/2018[2011-12]Status: DisposedITAT Ahmedabad25 Jul 2019AY 2011-12

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./Ita No. 222/Ahd/2018 "नधा"रण वष"/Asstt. Year: 2011-2012 Jaldeep Farms Pvt. Ltd., Income Tax Officer, 2Nd Floor, Sarthik Annexee, Vs. Ward-2(1)(2), Nr. Fun Republic, Ahmedabad. Satellite, Ahmedabad.

Section 10(1)Section 143(3)Section 2Section 2(14)

…ant has contended that it has shown the agriculture land as asset in the balance sheet, therefore, is to be taxed as a capital gain. I do not agree with the .appellant, since the Honourable Supreme Court in the case of Sutlej Cotton Mills Vs. CIT, West Bengal 116 ITR 1 has held that it is well settled that the way in which entries are made by an assessee in his books of account is not determinative of question whether the assessee has earned any profit or suffered any As appellant is a company engaged in the business of purchasing and selling of land, the profit is in the nature of adventure, and therefore, is to…

DCIT, Circle- 62(1), New Delhi vs. L&T Sucg Jv CC27, New Delhi

In the result, appeal of the Department is dismissed

ITA 4457/DEL/2018[2014-15]Status: DisposedITAT Delhi10 Jul 2019AY 2014-15

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: Shri Saurabh Goel, C.As And Shri Nirbhay MehtaFor Respondent: Shri J.K. Mishra, CIT-DR

…etical income which does not materialize. Thus, the Income Tax Act does not recognise hypothetical or notional income which is not received or accrued to the assessee. We rely upon Judgments of Hon’ble Supreme Court in the cases of Sutlez Cotton Mills vs. CIT 116 ITR 1 (SC); Tuticorin Alcali Chemicals and Fertilizers Ltd., 227 ITR 172 (SC) and Godhra Electricity Co. Ltd., 225 ITR 746 (SC). If this addition is considered in assessment year under appeal and stock position is taken differently, it has to be given effect in closing stock of this year, resultantly, opening stock of next assessment year would be enhanc…

L&T Sucg Jv CC27, New Delhi vs. Addl.CIT, Range-62, New Delhi

In the result, appeal of the Department is dismissed

ITA 4351/DEL/2018[2014-15]Status: DisposedITAT Delhi10 Jul 2019AY 2014-15

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: Shri Saurabh Goel, C.As And Shri Nirbhay MehtaFor Respondent: Shri J.K. Mishra, CIT-DR

…etical income which does not materialize. Thus, the Income Tax Act does not recognise hypothetical or notional income which is not received or accrued to the assessee. We rely upon Judgments of Hon’ble Supreme Court in the cases of Sutlez Cotton Mills vs. CIT 116 ITR 1 (SC); Tuticorin Alcali Chemicals and Fertilizers Ltd., 227 ITR 172 (SC) and Godhra Electricity Co. Ltd., 225 ITR 746 (SC). If this addition is considered in assessment year under appeal and stock position is taken differently, it has to be given effect in closing stock of this year, resultantly, opening stock of next assessment year would be enhanc…

DCIT, Alappuzha vs. M/S Aceelerated Freeze Drying Co, Ltd, Alappuzha

In the result, the appeal of the Revenue is allowed and the appeal of the

ITA 714/COCH/2008[2002-03]Status: DisposedITAT Cochin28 Jun 2019AY 2002-03

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

Section 143(3)Section 2Section 2(14)Section 42Section 50BSection 50B(1)

…mount arising out of restatement of foreign currency transactions taking into account the prevailing exchange rate as on the end of accounting year is liable to tax or not. The Supreme Court in the case of Sutlej Cotton Mills Ltd. Vs. CIT reported in [1979] 116 ITR 1 has held as under:- I.T.A. Nos. 714/Coch/2008 & 1286/Coch/2005 "The law may, therefore, now be taken to be well settled that where profit or loss arises to an assessee on account of appreciation or depreciation in the value of foreign currency held by it, on conversion into another currency, such profit or loss would ordinarily be a trading pro…

Aceelerated Freeze Drying Co.Ltd, Alappuzha vs. DCIT, Alappuzha

In the result, the appeal of the Revenue is allowed and the appeal of the

ITA 1286/COCH/2005[2002-03]Status: DisposedITAT Cochin28 Jun 2019AY 2002-03

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

Section 143(3)Section 2Section 2(14)Section 42Section 50BSection 50B(1)

…mount arising out of restatement of foreign currency transactions taking into account the prevailing exchange rate as on the end of accounting year is liable to tax or not. The Supreme Court in the case of Sutlej Cotton Mills Ltd. Vs. CIT reported in [1979] 116 ITR 1 has held as under:- I.T.A. Nos. 714/Coch/2008 & 1286/Coch/2005 "The law may, therefore, now be taken to be well settled that where profit or loss arises to an assessee on account of appreciation or depreciation in the value of foreign currency held by it, on conversion into another currency, such profit or loss would ordinarily be a trading pro…

The ACIT, Circle-2(1)(2), Ahmedabad vs. Mundra International Container Terminal Pvt. Ltd., Kutch

In the result, the appeal of the revenue is dismissed

ITA 2171/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad28 Jun 2019AY 2013-14
For Appellant: Shri S.N. Soparkar, A.RFor Respondent: Shri Alok Singh, CIT-D.R
Section 143(2)Section 14ASection 32

…es have held that foreign exchange fluctuation loss suffered on account of circulating capital or revenue account should be treated as revenue expenditure in the year in which the devaluation takes place when the method of accounting followed is mercantile. • 116 ITR 1 (SC) • 154 ITR 460 (Cal) • 90 ITR 323 (Ker) • 97ITD 125(Ahd) (TM) 151 para 8.28 Accordingly, this itself establishes that the Appellant has adopted the system of accounting which is fair and reasonable and supported by the Accounting Standard AS - 11, Rule 115 and various authorities and not adopted to avoid incidence of income tax. And in any case…

The ACIT, Circle-2(1)(2), Ahmedabad vs. M/S. Mundra International Container Terminal Pvt. Ltd., Kutch

In the result, the appeal of the revenue is dismissed

ITA 1117/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad28 Jun 2019AY 2012-13
For Appellant: Shri S.N. Soparkar, A.RFor Respondent: Shri Alok Singh, CIT-D.R
Section 143(2)Section 14ASection 32

…es have held that foreign exchange fluctuation loss suffered on account of circulating capital or revenue account should be treated as revenue expenditure in the year in which the devaluation takes place when the method of accounting followed is mercantile. • 116 ITR 1 (SC) • 154 ITR 460 (Cal) • 90 ITR 323 (Ker) • 97ITD 125(Ahd) (TM) 151 para 8.28 Accordingly, this itself establishes that the Appellant has adopted the system of accounting which is fair and reasonable and supported by the Accounting Standard AS - 11, Rule 115 and various authorities and not adopted to avoid incidence of income tax. And in any case…

ACIT, Haridwar vs. M/S Kirby Building Systems India (Uttaranchal) Pvt. Ltd., Haridwar

ITA 2626/DEL/2016[2008-09]Status: DisposedITAT Delhi14 Jun 2019AY 2008-09

Bench: Hon’Ble, Shri G.D. Agrawal & Shri Kuldip Singh

For Appellant: Shri Naveen Agarwal, FCAFor Respondent: Shri Surender Pal, Senior DR
Section 800ISection 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH ‘F’ : NEW DELHI) BEFORE HON’BLE VICE PRESIDENT, SHRI G.D. AGRAWAL and SHRI KULDIP SINGH, JUDICIAL MEMBER ITA No.2626/Del./2016 (ASSESSMENT YEAR : 2008-09) ACIT, Circle, vs. M/s. Kirby Building Systems India Haridwar. (Uttaranchal) Pvt. Ltd., Plot No.2, Sector 11, IIE, SIDCUL, Haridwar. (PAN : AACCK5926G) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Naveen Agarwal, FCA REVENUE BY : Shri Surender Pal, Senior DR Date of Hearing : 12.06.2019 Date of Order : 14.06.2019 O R D E R PER KULDIP SINGH, JUDICIAL MEMBER : Appellant, ACIT, Circle, Haridwar (hereinafte…

The ITO, Ward-2(1)(4), Ahmedabad vs. Medical Technologies Pvt. Ltd., Ahmedabad

In the result, the appeal is dismissed

ITA 3328/AHD/2016[2013-14]Status: DisposedITAT Ahmedabad03 Jun 2019AY 2013-14
Section 143(3)Section 41(1)

…ssessee within the meaning and scope of Section 2(24)(xvi)(i) of the I.T. Act. In this regard the appellant has relied upon the judgement of Hon'ble Supreme Court in the case of Kedarnath Jute Manufacturing Co. 82 ITR 3A3 and Satlaj Cotton Mills Ltd. Vs. CJT, 116 ITR 1 whereby it has been held that the accounting entries made in the books of accounts are not decisive in arriving at the conclusion as the taxability of a particular receipt. The receipt would become chargeable to fax only if it is a revenue receipt and falls within the definition of the term income as per Section 2(24) (xvi) (I) of the I.T. Act. Sin…

Ajb Developers Pvt. Ltd., New Delhi vs. DCIT, Circle- 2(1), New Delhi

In the result, appeal of Assessee allowed

ITA 7386/DEL/2018[2014-15]Status: DisposedITAT Delhi27 May 2019AY 2014-15

Bench: Shri Bhavnesh Saini, J.M. & Shri L.P. Sahu, A.M.

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri P.V. Gupta, Sr. D.R
Section 115JSection 2(14)Section 45

…hat income tax does not recognize hypothetical or notional income which is not received or accrued to the assessee. We rely upon the Judgments of Hon’ble Supreme Court in the case of Sutlez Cotton Mills Ltd., vs. Commissioner of Income Tax, West Bengal (1979) 116 ITR 1 (SC), in which it was held as under: “It is now well settled that the way in which entries are made by an assessee in his books of account is not determinative of the question whether the assessee has earned any profit or 19 ITA.No.7386/Del./2018 M/s. AJB Developers Pvt. Ltd., New Delhi. suffered any loss. The assessee may, by making entries which…

ITO, New Delhi vs. M/S. Citi Financial Cosumer Finance India Ltd., New Delhi

ITA 2638/DEL/2016[2009-10]Status: DisposedITAT Delhi23 May 2019AY 2009-10

Bench: Shri N.K. Billaiya & Shri Kuldip Singhito, Ward 6 (2), Vs. M/S. Citi Financial Consumer Finance New Delhi. India Ltd., 3, Local Shopping Centre, Pushpa Bhawan, Pushp Vihar, New Delhi – 110 062. (Pan : Aabca3223B) (Appellant) (Respondent) Assessee By : Shri C.S. Agarwal, Senior Advocate Shri Shailesh Gupta, Advocate Revenue By : Shri H.K. Choudhary, Cit Dr Date Of Hearing : 02.05.2019 Date Of Order : 23.05.2019

For Appellant: Shri C.S. Agarwal, Senior AdvocateFor Respondent: Shri H.K. Choudhary, CIT DR
Section 143Section 92C

…iew which the assessee might take of his rights nor can the existence or absence of entries in the books of account be decisive or conclusive in the matter". 25.4. Subsequently the Hon'ble Court re-affirmed the said view in Sutlej Cotton Mills. Ltd. Vs. CIT, 116 ITR 1(SC) " But it is now well settled that the way in which entries are made by an assessee in his books of account is not determinative of the question whether the assessee has earned any profit or suffered any loss. The assessee may, by making entries which are not in conformity with the proper accountancy principles, conceal profit or show loss and t…