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2012 (9) TMI 654 - ITAT AHMEDABADAddition on account of excess cash found in search u/s 132 - During Survey assessee made disclosure of Rs. 41 lacs comprising of excess cash of Rs 2 lac - In the profit and loss account the assessee had disclosed Rs. 41 lacs as “IT declared stock” and the same was offered for tax - AO had also made an addition on account of excess amount of cash of Rs. 2 lacs - Held that:- From the assessment order of the AO and the order of CIT(A) it is not clear as to whether the amount of Rs 41 lacs includes Rs 2 lac of excess cash found. In view of these facts, we are of the opinion that in the fairness of things and to meet the ends of justice this matter be remanded to the file of A.O for verification. Case remand back to AO. Addition on account of difference in stock found during survey u/s 132 - Assessee submit stock statement on the basis of purchases worked out on FIFO method inclusive of transportation and loading charges – AO made addition on basis of difference found in statement and stock shown in books of accounts – Held that:- As the discrepancy could not be reconciled and satisfactorily explained by assessee. The Assessee could not demonstrate before CIT(A) that the closing stock was without transportation charges and loading charges. The Ld. A.R. before us also could not demonstrate with any tangible evidence the correct working of stock. Therefore appeal decides in favour of revenue.
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