2022 (5) TMI 1373

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....is directed against the order passed by the CIT (Appeals)-1, Kolhapur on 07-08-2018 in relation to the assessment year 2009-10. 2. The assessee has raised two issues in its grounds of appeal namely, addition of Rs. 8,43,230/- on account of excess stock and addition of Rs. 4,00,100/- on account of excess cash - found during the course of survey. The ld. AR did not press the addition of excess ca....

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....the assessee submitted that it had, vide its letter dated 15-04-2009, put forth the contention that some purchase bills were received after the date of survey which were not considered even though the goods had been received prior to that which were included in the actual stock. The AO rejected this contention and made the addition. The ld. CIT(A) affirmed the action of the AO. 4. I have heard ....

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....-, whereas the inventory as per books of account was only Rs. 2,09,832/-, leading to excess stock of Kirana items at Rs. 8,43,230/-. The assessee admitted that he was not able to explain the difference and agreed to offer the additional income of Rs. 8,43,230/- for the year under consideration, which was actually not offered. On 15-04-2009, i.e. after more than two months from the date of survey, ....

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....count as these were received post-survey though the goods were included in the inventory as on the date of survey. The ld. AR, on requisition, failed to lead any evidence to the effect that the goods against such invoices were received before the date of survey but the invoices were not entered as these were received later on. Given the fact that the actual stock was counted at the time of survey,....