2013 (12) TMI 664

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....postings of the day was not complete at the time of survey but were completed during the course of survey All the books of account were available. While preparing trading account for ascertaining closing stock as on the date of survey, one bill qua purchase of Rs. 2,16,900/- was not available on spot but the goods as per that bill were stated to received and unloaded in the godown. According to assessee this stock was included in the inventory prepared by the Survey team. The controversy is regarding the excess stock found during the course of survey. A statement of the assessee was recorded on 9.11.2004. While explaining the stock found on physical verification in excess of what was recorded in the books of account, the assessee had agreed....

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....had certified the correctness of the physical stock taken. In that statement, Shri Chopra had also referred to some defects in the stock taking and in its valuation but before the Assessing Officer he could not pin point any such defect despite opportunity given to him. Accordingly, the learned C IT(A) has also upheld the addition of Rs. 2,16,900/-. Now, the assessee has come in appeal before us. 4. Almost all sorts of arguments which were taken before the lower authorities have also been taken before us during hearing. The learned ld. AR has filed a paper book containing inventory taken during survey and copy of the written submission filed before the CIT(A). He has also filed copies of orders including that of Hon'ble Jodhpur Bench in ....