Total Pageviews

Monday 26 October 2015

Survey party compared the physical stock found with figures of RG-1 register maintained by the assessee in which discrepancies with physical inventory were found—AO made the addition of Rs. 5,58,54,128 on account of unexplained investment in stock—Appraisal report prepared at the time of survey party is valuable information to reject books of account but same is not a final assessment but it is of assistance in making assessment—Merely on the basis that at the time of survey, some differences were found in stock that does not mean that there will be an automatic addition on account of differences—AO and CIT(A) both have failed to point out how the reconciliation submitted by the assessee was incorrect—Such differences are always subject to explanation and reconciliation—Assessee has reconciled the differences with reasons and the Revenue authorities did not point out anything contrary that how the reconciliation done by the assessee was incorrect—Addition cannot be made unless it is found that the stock was sold out of books of account, hence same can not be sustained-CHAWLA BROTHERS (P) LTD. vs. ASSISTANT COMMISSIONER OF INCOME TAX (2011) 43 SOT 0651


No comments:

Post a Comment