2019 (2) TMI 719

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.... stray and isolated figures which stood reconciled, addition is made which is ex facie incorrect and made mechanically. ii) That assessee's alternate claim to allow automatic deduction u/s. 80JJA on aforesaid addition of Rs. 14,62,636/- has been denied on invalid reasons and against the binding and cited CBDT Circular No. 37/2016. iii) That addition sustained by Ld. CIT(A) to the extent of Rs. 470,000 is incorrect and alternatively enhanced deduction benefit u/s. 80JJA must be given to the assessee as claimed. Humble prayer:- (i) To delete the addition of Rs. 14,62,636/- on account of alleged non disclosure of closing stock; alternatively deduction and benefit u/s. 80JJA; (ii) To delete the addit....

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....he heads consumables, power/ fuel, packing, freight, miscellaneous, telephone, conveyance, travelling etc. as no vouchers were produced for expenditure claimed as Rs. 47 lacs (as per the table given at page no. 5 of the assessment order) and added the expenses are not considered as genuine and addition of Rs. 11,75,190/- was made to the income of the assessee. Accordingly, the income of the assessee was assessed at Rs. 27,77,280/- u/s. 143(3) of the Act vide order dated 22.08.2016. Against the assessment order, assessee appealed before the Ld. CIT(A), who vide his impugned order dated 05.6.2017 has partly allowed the appeal of the assessee. Aggrieved with the impugned order, assessee is in appeal before the Tribunal. 3. During the hearin....

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....f closing stock is concerned, I note that the AO has made addition on account of non-disclosure of closing stock of Rs. 14,62,636/- as it was not shown in column 4 of Part A, P&L in the income tax return. This has resulted in less profit and suppression of income. I further find that AO observed that excess of assets in the shape of closing stock is his profit, which is not declared as income by the assessee. The assessee's claim that he should get benefit of provision of deduction u/s. 80JJA of the Act is not tenable because the addition has been made on account of undisclosed closing stock of Hindustan Sanitary Plaza, and this concern dealing in sanitary items. As this income is not derived from the activity of manufacturing which is cove....