2024 (10) TMI 749

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....L (1046) FOR THE APPELLANT MR B S SOPARKAR(6851) FOR THE OPPONENT ORAL ORDER (PER : HONOURABLE MR. JUSTICE BHARGAV D. KARIA) 1. By this Tax Appeal under Section 260A of the Income Tax Act, 1961 (for short 'the Act'), the appellant revenue has proposed the following questions of law arising out of order dated 31st August, 2022 passed by the Income Tax Appellate Tribunal, Ahmedabad (for ....

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....0 declaring total income at Rs. 32,18,030/-. The case of the assessee was re-opened and order under Section 143(3) read with Section 147 of the Act was passed on 24th November, 2015 by assessing total income at Rs. 03,25,30,540/- by making an addition of Rs. 02,93,12,514/- on account of Section 69C of the Act. 2.2 Being aggrieved by the said order, appeal was preferred before CIT(A). The ....

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.... the findings given by the CIT(A) in the order for Assessment Year 2009-10. 3.1 However, the Tribunal, after considering the facts of the case, came to the conclusion that the opening stock is shown by the assessee as closing stock in the previous Assessment Year 2009-10, the CIT(A) found that closing stock of Rs. 02,93,12,514/- shown by the assessee was utilised for making unaccounted sale, me....

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....ing of learned CIT (A) in the own case of the assessee for immediate previous assessment year i.e. A.Y. 2009-10 where the learned CIT(A) found that the closing stock of Rs. 2,93,12,514/- shown by the assessee was utilized for making unaccounted sale meaning thereby no actual closing stock available. Thus, it means that the opening stock carried forwarded from A.Y. 2009-10 in the year under conside....