TMI Blog2022 (4) TMI 578X X X X Extracts X X X X X X X X Extracts X X X X ..... irections by the AO to produce the stock register wherein the receipt of goods in question were entered by him, had however, failed to do the needful. We concur with the view taken by the lower authorities that the assessee in the grab of its claim of having made purchases had in fact tried to neutralize the amount of undisclosed income that was surrendered by it in the course of the survey proceedings - we find no infirmity in the view taken by the CIT(Appeals) who had on the basis of well-reasoned order sustained the addition made by the Assessing Officer. We, thus, in terms of our aforesaid observations uphold the order of the CIT(Appeals) qua sustaining of the addition made by the Assessing Officer. - Decided against assessee. - IT ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2011-12 on 29.09.2011, declaring a loss of Rs. (-) 11,16,579/-. On verification of the Profit loss account, it was observed by the Assessing Officer that the assessee had disclosed the entire amount of surrendered income under the head 'Other income'. On a conjoint perusal of the Profit loss account provided by the assessee to the survey team for the period 01.04.2010 to 29.03.2011 and the audited Profit loss account, it was, inter alia, observed by the Assessing Officer that there were differences in the trading account. Observing that the assessee had not carried out any trade between 30.03.2011 to 31.03.2011, the Assessing Officer called upon it to explain the aforesaid difference. In reply, the assessee filed a reconcilia ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... books of account and relevant documents were duly verified and inventorised, the Assessing Officer was of the view that in case any entry had remained omitted to be recorded in the books of account, then, the assessee ought to have informed the said fact, which however was not done at the relevant point of time. Backed by the aforesaid facts, the Assessing Officer was of the view that the concocted story projected by the assessee was nothing but an attempt on its part to inflate the expenses in the grab of bogus entries of purchases of raw materials and stores aggregating to ₹ 13,75,203/-. Accordingly, the Assessing Officer disallowed the assessee's claim for deduction of expenses incurred towards purchase of raw materials and sto ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... claim on the basis of irrefutable documentary evidence. As observed by us herein above, the assessee despite specific directions by the Assessing Officer to produce the stock register wherein the receipt of goods in question were entered by him, had however, failed to do the needful. Backed by the aforesaid facts, we concur with the view taken by the lower authorities that the assessee in the grab of its claim of having made purchases of ₹ 13,75,203/-, had in fact tried to neutralize the amount of undisclosed income that was surrendered by it in the course of the survey proceedings. Considering the totality of facts involved in the case before us, we find no infirmity in the view taken by the CIT(Appeals) who had on the basis of well ..... X X X X Extracts X X X X X X X X Extracts X X X X
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