2022 (11) TMI 474

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... circumstances of the case, the CIT- (A) erred in deleting the addition of Rs.4,10,00,000/- on unexplained expenditure u/s 69C of the Act, by relying on its decision in the assessee's case for A.Y. 2012-13. 2. The appellant craves to leave, add, amend or alter the ground(s) of appeal on or before the appeal is heard and disposed off." 2. In this case the facts as emanating from the assessment order are as under : "5.1 Survey action u/s. 133A of the I. T. Act was carried out in the case of assessee on 02/02/2012. During the course of said survey, several incriminating documents were found and impounded. Majority of these incriminating documents related to payments of speed money to Government officials, land records offi....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ngly increased by the assessee by the amount of disclosure) would get reduced by an amount of Rs. 4.10 crores being addition made under Sec. 69C for A.Y. 2012-13. Accordingly, this reduced closing stock / WIP of F.Y.2011-12 would become opening stock / WIP for F. Y. 2012-13. In other words, the opening stock / WIP for the year under consideration i.e. A.Y. 2013-14 has to be reduced by Rs. 4.10 crores as a cascading effect of addition u/s. 69C in assessee' case for A.Y. 2012-13. 5.6 In view of the foregoing facts and as a consequence of assessment order for A.Y. 2012-13 in the case of assessee, (making addition u/s. 69C), an addition of Rs. 4.1 crores is made to the total income of the assessee on account of reduction of opening sto....