Dismissing the appeal of the assessee the Court held that,  the excess stock, per se, had to be brought to tax as undisclosed income and there was no justification for or question of giving corresponding deduction to the extent of any purchase or source of incurring such expenditure or unexplained investments. When the excess stocks were found during the survey, there was no question of allowing the assessee to record any additional purchases because such purchases had already been recorded in the books of account of the assessee. S. 69B which provided for bringing to tax investments in bullion, jewellery or other valuable articles (including excess stocks) would have been the more appropriate section to have been indicated in the orders passed by the authorities below rather than under S.  69C as unexplained expenditure. Mention of the wrong section in the order would not upset the additions made by the assessing authorities below. No question of law arose. (AY. 2014-15)