TaxTMI 
TaxTMI 
2018 (2) TMI 2103
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....cross-objection filed by the assessee being C.O. No. 18/Ran/2014. 2. First we shall take up the appeal being ITA No. 171/Ran/2014 filed by the assessee. 3. Ground no 1 is relating to sustaining the addition of Rs. 47,94,499/- made on account of undisclosed stock. The A.O. basing on the impounded documents that were found during the survey under 133A of the Act prepared a comparative analysis of stock of different items along with their respective values found physically and the position of stock recorded in the books of accounts and found value of excess stock to the extent of Rs. 47,94,499/-. For non explanation and non reconciliation of the excess stock and basing on certificate of valuation of physical stock issued by BCCL, without con....
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.... by the assessee. 6. Heard rival submissions and perused the material available on record. We find that under identical facts, the Co-ordinate Bench of ITAT, Ranchi remanded the issue to the file of the A.O. to conduct and consider the issue de novo in terms of the decision of Hon'ble Supreme Court in the case of Sahara India reported in 300 ITR 403 (SC). The relevant portion of which is reproduced herein below: "We find that the assessee has also reiterated its objection before the learned CIT(Appeals) but the learned CIT(Appeals) has not commented on this aspect. Upon careful consideration, in our considered opinion, it was incumbent upon the authorities below to give proper reasons as to why they are rejecting the preliminary objectio....
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.... by following the same, we deem it proper to remand the issue in ground no 3 to the file of A.O. by taking into consideration submissions of both the parties before us. Therefore, ground no 3 of the assessee is allowed for statistical purposes. 10. Now, we shall take up the appeal in ITA No. 252/Ran/2014 filed by the revenue. Ground raised by the revenue is read as under: "1. That the Ld. CIT(A), Dhanbad, has grossly erred in allowing telescoping of excess stock against undisclosed profit which were two independent set of events having no nexus whatsoever. 2. Any other ground that may be raised during the course of hearing" 11. It is noticed that the revenue has raised ground challenging the action of CIT(A) in allowing telescoping ....