2011 (12) TMI 521

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....DGMENT : Revenue is in appeal against the judgment of the Tribunal dated 1st April 2010, raising following question for our consideration :- [A] "Whether on the facts of the case and in law and in the circumstances, the Appellate Tribunal was right in law and on facts in deleting the addition of Rs. 46,55,111/= being the difference of value declared in the stock statement given to the Bank a....

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....t proceedings. ?" Though questions are multiple, the central question is with respect to description of the closing stock ie., the one reflected in the statement submitted to the bank for the purpose of hypothecation of the goods, as compared to the stock statement filed before the Income-tax authorities. The Assessing Officer as well as the CIT [A] both were of the opinion that the statemen....

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....ents. The Tribunal, however, was of the opinion that the statement supplied to the Bank was on estimate basis. When the assessee had successfully explained the discrepancy, the Tribunal accepted the assessee's version that the statement to the Bank was not only on the estimated basis but was also made on the higher side for availing higher loan facility. The Tribunal also recorded that on t....