2001 (11) TMI 973

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....he Assessing Officer for a sum of Rs. 2,46,552 as a result of survey conducted on the premises of the assessee. Narrating the facts, he contended that a survey was carried out at the premises of the assessee on 26-10-1988 wherein it was found that the stock of the assessee was less as compared with the stock as per books to the tune of Rs. 2,97,050. He contended that physically counted stock was arrived at Rs. 17,77,161 whereas as per books the stock of the assessee was Rs. 20,74,211. When the assessee was asked to explain the discrepancy, the answer of the assessee was that he was unable to explain the difference. However, the same was offered for taxation for the year under consideration. Referring to question No. 19 and answer thereto, h....

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....ess stock found to be shown as sales and the same was shown as sale. He contended that if the addition made by the Assessing Officer is considered for arriving at gross profit the gross profit as assessed will come to 20.94 per cent. The kind of profit arrived at after adding the sum by the Assessing Officer was never accrued to the assessee as the gross profit in the preceding years ranges between 14 per cent to 17 per cent and it never crossed 17 per cent. He further placed reliance on the decision of Tribunal Pune Bench in the case of Janta Tiles v. Asstt. CIT [2000] 66 TTJ (Pune) 695. In this case, the stock found at the time of search was less than the stock as per the books. Thus, it was found that difference of Rs. 1,96,924 represent....