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2020 (8) TMI 472 - AT - Income TaxUnexplained investment in stock and spares - Addition u/s 69A - HELD THAT:- It is the not the case of the Revenue that the assessee has not accounted for certain purchases and is having excess stock than what is shown in its books of account. Moreover, the AO has not denied that the assessee has capitalised stock of stores and spares to the plant and machinery. The value of stock and spares is found to be capitalised in the plant and machinery and, therefore, the same could not have been found in the closing stock shown in the books of account. Stock of stores and spares which have been shown to the bank are reflected in the books of account under the head ‘Plant and Machinery’ as the same were capitalised. Except for this, there is no evidence brought on record to suggest that the assessee has made investment in its stocks outside the books of account. Considering the totality of the facts, we are of the considered view that the provisions of section 69A of the Act do not have any application on the facts of the case in hand. We, accordingly, direct the Assessing Officer to delete the addition - Decided in favour of assessee.
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