Dy. CIT v. Plasto Electronics Pvt. Ltd. (2022)95 ITR 93 / 218 TTJ 1 (SN)(Kol) (Trib)

S. 69 : Unexplained investments-Survey-Undervaluation of stocks-Reconciliation statement filed-Addition is not justified. [S. 133A]

Held that there were several infirmities and mistakes committed by the survey team while doing stock-taking physically. In the reconciliation statement, the assessee had explained the stock differences minutely. It showed that the survey team had even omitted the stock to the extent of Rs.36,80,834.34 while calculating the excess stocks by committing various mistakes such as double accounting of stocks, wrong application of rates and various other reasons. None of the authorities had pointed out how the stock reconciled by the assessee was not correct. Therefore, the difference in stock inventory was only to the tune of Rs. 3,81,063.09. Accordingly the order of the Commissioner (Appeals) was to be modified and the Assessing Officer was to restrict the addition to Rs. 3,81,063.09.(AY.2015-16)