2023 (10) TMI 1019

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....ances of the case the action of the Ld. CIT(A) to confirm the addition made by the AO of Rs. 14,66,622/- on account of unexplained investments u/s 69B of the Act is contrary to the material evidences of record and the addition is arbitrary, excessive and illegal. 2. That on the facts and in the circumstances of the case the action of the Ld. CIT(A) to confirm the addition made by the AO of Rs. 11,00,120/- on account of publicity expenses not accounted for in the receipt sides of the books is contrary to the material evidences of record and the addition is arbitrary, excessive and illegal. 3. That the order of the Ld. CIT(A) confirming the action of the A.O. is arbitrary, excessive and illegal. 4. That the above gr....

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....essee. In the appellate proceedings Ld. CIT(A) simply affirmed the order of the AO on the same reasoning. 5. After hearing the rival contentions and perusing the material on record, we find that the assessee is dealing in liquor which is an excisable item and passes through various checks and scrutinies by the Excise Department. We note that the assessee has maintained stock register recording therein opening stocks, purchases, sales and closing stocks including item-wise identification of each brand. Similarly, the assessee has maintained the excise register also. Both these were produced before us and were test checked by us. We observe from the assessment order that the AO while taking a few items out of the total items calculated the....