TaxTMI 
TaxTMI 
2013 (9) TMI 1065
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..../- made on account of alleged difference in opening stock price and Sale price of trading account, in utter disregard of the explanation rendered during the course of appellate proceedings which is arbitrary and unjustified especially when the sales are fully vouched. 2. That the assessee is maintaining regular books of account which are duly audited one and without pin-pointing any mistake whatsoever, in the maintenance of accounts, the upholding of the addition of Rs. 41,24,000/- based on no adverse material brought on record but only on suspicion, assumptions, surmises and conjectures is illegal, arbitrary and unjustified. 3. That the submission filed before the Commissioner of Income tax (Appeals) have not been considered much ....
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....5 x 1995 598001 4 Rice Sharbati 2200/qntl - 1448 2449 1001 x 2200 2708455 Total 4124000 In this background a sum of Rs. 41,24,000/- was added to the income of the assessee. 4. On appeal before the CIT(A) it was submitted that in case of bardana price of opening stock is as per the purchase price. Bardana was being sold by the assessee alongwith rice and bardana itself was not being sold. Baradana was being used number of times from lifting the paddy from the Mandis, drying process of the paddy, husking the paddy and finally for filling the paddy products in the business of rice shellers. Thus, bardana undergo heavy wear and tear and accordingly the same was billed at a lower rate.....
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.... of coverting paddy into rice, 2/3 varieties of rice comes which is called full rice, rice broken which include Doubar / tibar rice, kinki rice and rice nakko and rice bran. It was further pointed out that broken contents including rice dubar, tibar and kinki and nakko varies from 28% to 35% subject to quality of the paddy. The assessee has managed to keep the broken content at 30%. It was pointed out that no rice DB was sold and the only broken rice DB was sold to the tune of 299.75 quintals and balance of broken rice was lying in the stock. It was submitted that once the Assessing Officer was satisfied in the valuation of the closing stock he cannot change the selling price of the goods. 4.3 In respect of rice sharbti it was stated that....