2020 (11) TMI 859

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....the facts and in the circumstances of the case, the ld. CIT (Appeals) has erred in deleting the disallowance of Rs. 6,09,43,809/- made by the Assessing Officer on account of difference in opening stock outside the books of accounts. 2. The ld. CIT (Appeals) erred in law in admitting additional evidence under Rule 46A without giving an opportunity to the Assessing Officer. 3. The appellant craves leave for reserving the right to amnd, modify, alter, add or forego any ground(s) of appeal at any time before or during the hearing of this appeal. " 3. The assessee company was engaged in the business of manufacturing of sponge iron and steel products and has two divisions i.e. sponge iron and power division in Raigarh and rol....

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.... Rs. 6,09,43,809/- treating it to be stock sold outside books of accounts. The Assessing Officer also disallowed deduction under Section 80IB of the Act to the extent of Rs. 7,09,944/-. 4. Being aggrieved by the assessment order the assessee filed appeal before the CIT (Appeals) and the CIT (Appeals) partly allowed the appeal of the assessee. 5. The Ld. DR submitted that the CIT (Appeals) erred in deleting the disallowance of Rs. 6,09,43,809/- made by the Assessing Officer on account of difference in opening stock outside the books of accounts. The Ld. DR submitted that the assessee company asked to furnish the details of deduction claimed under Section 80IB of the Act and also show cause as to why the excess deduction made not be ....