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TMI Blog2015 (10) TMI 173X X X X Extracts X X X X X X X X Extracts X X X X ..... t the assessee is engaged in the business of manufacturing and trading of jewellery, bullion. The return of the assessee was selected for scrutiny. During assessment proceedings, the A.O. observed that the assessee was availing a cash credit facility form Indian Overseas Bank and, therefore, he issued summons u/s 131 of the I. T. Act, 1961 to Manager, Indian Overseas Bank, requiring him to file a copy of stock statement as on 31.03.2006 and 31.03.2007. During the course of assessment proceedings the assessee had also furnished valuation details of closing stock as on 31.03.2007. The A.O. observed that there was difference in value and quantity in respect of certain items of jewellery as also there was difference in value of two stock statem ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... process (gold bar) - - 78% Gold jewellery 3,818.750 2,902,250.00 83% Gold jewellery 18,288.302 13,789,434.82 92% Gold jewellery 9,173.742 8,258,387.80 75% Gold jewellery mounting 115.615 84,388.95 75% Gold jewellery 7,883.744 5,740,533.12 Total (Rounded off) 3,07,66,198 Stock statement as on 31.03.2007 (as per books of accounts) Item Quantity Value 24 Ct. Gold Bar 0.000 - 75% New gold chain & jew. 7863.744 5721063.00 78% New gold chain & jew. 118.483 90225.00 83% New gold chain & jew. 9330.433 7794855.00 92% New gold chain & jew. 19411.212 18148887.00 Alloys & mixing l3214.375 378.00 Mounting 75% 115.615 83711.00 Total (Rounded off) 3 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s of the case, I hold that the assessing officer was not justified in making the said addition of Rs. 87,86,604/-, and therefore, ground no.2 is allowed." 3. Aggrieved, the Revenue is in appeal before us. 4. At the outset, Ld. D.R. read para 2.4 and 2.5 of the assessment order and submitted that the contention of the assessee that different stock statements were given to bank for availing more credit facility, is not correct as in fact, there was excess stock as per books of account of the assessee as compared to the bank statements. He further argued that on a particular date, how the two statements can have different quantities of various kinds of jewellery. It was submitted that Ld. CIT(A) had wrongly decided the issue in favour of the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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