Revision petition dismissed for stock shortage addition under Section 264 - entire shortage taxable as off-books sales

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....HC dismissed revision petition under Section 264 challenging addition to total income for stock shortage discovered during Central Excise survey. Assessee contended only gross profit should be added, not entire shortage amount. Court upheld Revisional Authority's finding that assessee failed to provide satisfactory explanation for discrepancy during assessment or penalty proceedings. Assessee had accepted stock shortage as sales outside books and paid excise duty accordingly. Since raw material costs were already accounted in regular books, entire off-books sales constituted taxable income requiring full addition. Court noted penalty proceedings under Section 271(1)(c) remain separate from assessment proceedings, rendering revision petition ineffective for appellate relief against penalty.....