TMI Blog2018 (11) TMI 472X X X X Extracts X X X X X X X X Extracts X X X X ..... t 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. - ITA No.1495/Ahd/2014 And ITA No.1206/Ahd/2015 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2. Channel 7.818 3. Plate 1.021 4. Beam/Joist 5.884 Total 17.393 Asstt.Year 2010-11 Sr. No. Particulars Shortage (MT) Excess 1. Angle 2.835 2. Channel 9.330 3. Plate 0.160 4. Beam/Joist 4.805 Tota ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lied above shortage with average value of the stock available with the assessee in the closing stock and worked out addition in both the years. Appeal to the ld.CIT(A) did not bring any relief to the assessee. 6. Before us, the ld.counsel reiterated his submissions as were taken before the AO. On the other hand, the ld.DR submitted that item in which the assessee has been dealing is of such a nature where shortage would not happen. 7. On due consideration of the above facts and circumstances, we are of the view that the assessee is not dealing in perishable items or any items such as coal, sand, petroleum products etc. which can be considered as those items, which can result in pilferage or evaporation or shrinkage etc. The assessee h ..... X X X X Extracts X X X X X X X X Extracts X X X X
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