Excess stock addition sustained where search findings were factual and later stock-register explanation failed to displace them.

Excess stock found during search was treated as a factual issue, and the assessee's later reliance on a stock register did not dislodge the finding that no register was available at the relevant time. The Assessing Officer made an addition, the Commissioner (Appeals) deleted it, and the Tribunal restored a reduced addition. As the controversy was essentially fact-driven and the Tribunal had already granted substantial relief, the High Court found no ground to interfere. The addition was therefore sustained to the extent of Rs. 1 lakh, and the challenge failed.

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Issues: Whether the addition sustained on account of excess stock found during search could be interfered with in appeal.

Analysis: The dispute turned on facts relating to excess raw material found during search and the absence of a stock register at that stage. The assessee's later explanation based on the stock register was not accepted as sufficient to dislodge the factual finding. The Assessing Officer had made an addition of Rs. 2,35,953, the Commissioner (Appeals) deleted it, and the Tribunal restored a reduced addition of Rs. 1 lakh. Since the matter was essentially factual and the Tribunal had already granted substantial relief, no ground was made out for interference.

Conclusion: The addition was upheld to the extent of Rs. 1 lakh and the challenge failed.

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