2014 (7) TMI 380

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..... e assessee is directed against the order of learned CIT(A)-I, New Delhi dated 7th February, 2012 for the AY 2007- 08. 2. The assessee has raised the following grounds of appeal:- "1. The ld.CIT(Appeals) erred in law and on facts in confirming the assessment framed u/s 144 of the Act without affording a reasonable and adequate opportunity to the assessee. Thus, the assessment so framed is bad in .....

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..... that the assessee was carrying on a very small business of retailing of spices of MDH brand to hotels and restaurants. The smallness of the assessee's business is evident from the fact that during the course of survey, total stock found was only of Rs. 1,80,517/- and cash of Rs. 1,12,957/-. That the Assessing Officer estimated the income from such retail trade at Rs. 4 lakhs, made the addition of .....

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..... nd perused relevant material placed before us. Insofar as the addition of stock is concerned, we find that the total stock found was of Rs. 1,80,517/-. When the assessee is carrying on the business, some stock is bound to be there. The Assessing Officer has estimated the income at Rs. 4 lakhs. In such circumstances, the stock of Rs. 1,80,517/- cannot be said to be excessive or unreasonable even if .....

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