2017 (3) TMI 743

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.... assessee had accepted the value of the closing stock as per the books of accounts Rs. 16,95,184/- and value of the physical stock at Rs. 66,98,216/- and assessee surrendered the difference of Rs. 50,03,032/- as pointed out by the Assessing Officer and the Assessing Officer has reproduced the statement of Shri Ankur Arora and Dilip Kumar Arora in extenso. Finally the Assessing Officer made additions of Rs. 44,05,090/- in regard to unexplained investment in excess based on the cogent evidence came on record and that came to be challenged by the assessee before the Commissioner of Income Tax (Appeals) and the question arose before the Commissioner of Income Tax (Appeals) was follows:- "That under the facts & circumstances of the c....

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.... construction and made the new construction thereon as per the facts stated above. Accordingly the addition made by the AO of Rs. 2,75,587/- is deleted." The order of Commissioner of Income Tax (Appeals) was subject matter of challenge at the instance of the assessee before the Income Tax Appellate Tribunal and in para-3 of order of the Income Tax Appellate Tribunal, detailed reasons have been assigned which are nothing but the factual narration which were recorded during the course of survey conducted on 03.02.2011 and finally arrived to the conclusion in para-5 of the order as follows:- "5. We have heard the rival contentions and carefully perused the material available on record. In terms of ld AR's contention that there was ....