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TMI Blog2022 (11) TMI 474X X X X Extracts X X X X X X X X Extracts X X X X ..... is directed to delete the addition made for A.Y. 2013-14. Accordingly, grounds of appeal of Revenue are dismissed. - ITA No. 210/PUN/2018 - - - Dated:- 2-11-2022 - SHRI S. S. GODARA , JUDICIAL MEMBER AND DR. DIPAK P. RIPOTE , ACCOUNTANT MEMBER Assessee by Shri V. L. Jain AR Revenue by Shri S. P. Walimbe DR ORDER PER DR. DIPAK P. RIPOTE, AM: This appeal filed by the Revenue is directed against the order of ld. Commissioner of Income Tax(Appeals)-8, Pune, dated 27.10.2017 for the A.Y. 2013-14 under section 250 of the Income Tax Act, 1961(in short the Act ). The Revenue has raised the following grounds of appeal: 1. Whether on the facts and circumstances of the case, the CIT- (A) erred in deleting the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... for A.Y. 2012-13, the AO has reduced the disclosure of Rs. 4,10,00,000/- from business income and has added it separately specifically stating that it was an addition u/s. 69C for which no other deduction is allowed. For the sake of ready reference, copy of assessment-order for A.Y. 2012--13.dated 30/03/2015 is enclosed as Annexure-A of this order. 5.2 As a result and consequence of AO s action for A.Y. 2012-13, since the said disclosure of Rs. 4.10 crores has been held to be unaccounted expenditure, it would have an impact on the closing stock / WIP of the assessee for the year ending on 31/03/2012. Thus, the closing stock / WIP as on 31/03/2012 (which was wrongly increased by the assessee by the amount of disclosure) would get red ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . 2012-13 which has been deleted by the ld.CIT(A). Hence, there is no merit in the addition for A.Y. 2013-14. The ld.AR supported the order of the ld.CIT(A). 5. On the other hand, the ld.Departmental Representative(ld.DR) for the Revenue supported the order of Assessing Officer. 6. We have heard both the parties and perused the records. As mentioned in earlier para, the AO made an addition of Rs.4,10,00,000/- under section 69 for A.Y. 2012-13 on the ground that assessee has wrongly added survey declaration to its closing stock for A.Y. 2012-13. The AO therefore said that since closing stock for A.Y. 2012-13 becomes opening stock for A.Y. 2013-14, there needs to be an addition of Rs.4,10,00,000/- for A.Y. 2013-14. However, the ld.CIT(A ..... X X X X Extracts X X X X X X X X Extracts X X X X
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