2020 (8) TMI 472

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....ned investment in stock and spares. 3. Briefly stated, the facts of the case are that the assessee is engaged in the business of manufacturing of black and galvanized steel tubes. During the course of scrutiny assessment proceedings, the Assessing Officer called for stock details as on 31.03.2011 from Punjab National Bank. These details were confronted to the assessee and the assessee was asked to reconcile the discrepancies in the stock position shown to the bank over that reflected in the account books. 4. In its reply, the assessee submitted that quantitative details of finished goods and raw materials as per books of account and bank statement are in agreement. It was explained that the value of stock and spares is given to the ba....

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....ssessee reiterated what has been stated before the lower authorities. It is the say of the ld. counsel for the assessee that even the Inspection Report of the Senior Manager of Punjab National Bank clearly shows that quantity and value given for the stock and stores agrees with the Borrowers Stock Register and system followed for valuation of stock and spares is as per the terms of sanction. 11. It is the say of the ld. counsel for the assessee that the lower authorities have grossly erred in not understanding the facts in true perspective. The ld. counsel for the assessee stated that though the stock of stores and spares have been given separately to the bank, but the same has been capitalised in the books of account under the head 'Pla....