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2018 (11) TMI 472 - AT - Income TaxAddition of closing stock - Shortage of closing stock - AO multiplied the shortage with average value of the stock available with the assessee in the closing stock and worked out addition in both the years - Held that:- Explanation of the assessee is plausible because on account of different weigh-bridges, possibility of different measurements in weight could not be ruled out. However, the assessee has been showing the loss consistently in the same ratio on similar products In the asstt.Year 2009-10, it has made purchases of 9990.716 MTs. In the next year it has made purchases of 10995.363 MTs. and in both the years, the loss claimed at 17.393/17.130 MTs. It creates a suspicion of being adopted a particular modus operandi by the assessee to inflate purchases and manipulate value of closing stock, but again we do not have any supporting evidence qua this suspicion. Therefore, looking to the facts and circumstances, we are of the view that an adhoc disallowance to the extent of ₹ 2,00,000/- in each assessment year is being sustained, then it can take care of any such steps at the end of the assessee. Accordingly, addition is restricted to ₹ 2,00,000/- (Rupees Two Lakhs only) to each assessment year and the balance in both the years is deleted. Ground of appeal of the assessee in both the years is partly allowed.
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