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2020 (2) TMI 575 - HC - Income TaxDiscrepancy between the stocks as per books of account and as per bank records - addition in view of the statements given by the bank officials that the stocks statement as furnished on 31.3.1988 continued to be reflected in their accounts being upto 28.4.1988? - HELD THAT:- The contention is that the stock was from the hypothecated stock of ₹ 20,00,000/- odd. To substantiate the said claim, no evidence was produced before the authorities. The bank was never informed that the hypothecated stock was reduced and out that ₹ 12,00,000/- odd of stock was pledged. The assessee failed to discharge the onus of explaining the discrepancy. The matter can be viewed from another angle, i.e., as and when there was additional stock of ₹ 3,44,000/-, the assessee approached the bank to show that the stock had increased. The said stock was pledged with the bank on 29.4.1988 and thereafter drawing power was enhanced by ₹ 2,33,600/- and accordingly the value of stock was changed by the bank. The value of hypothecated stock as on 31.3.1988 was repeated subsequently on 16.4.1988 and 24.8.1988 as there was no change of value of stock and the same was not informed to the bank. The assessee failed to prove incorrectness of entries of D.P. Register. The evidence was duly considered by the Tribunal and partial relief was granted. No illegality is shown in the order of the Tribunal sustaining addition - Decided against assessee.
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