Tribunal held that at no point of time had the books of account been rejected by the Assessing Officer. There was no denial by the Assessing Officer that stocks were lying outside the factory premises and cold storages. The Assessing Officer had not pointed out any defect in the reconciled stock. The Commissioner (Appeals) had also not taken cognizance of the proper gross profit rate applied. Therefore, the Assessing Officer as well as the Commissioner (Appeals) had not considered the actual material in consonance with the physical stock. The assessee had justified its difference through documents which were at no point of time doubted by any of the Revenue authorities. Therefore, the Commissioner (Appeals) was not justified in sustaining the addition on account of difference in stocks. (AY. 2012-13)