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TMI Blog2020 (8) TMI 472X X X X Extracts X X X X X X X X Extracts X X X X ..... fly stated, the facts of the case are that the assessee is engaged in the business of manufacturing of black and galvanized steel tubes. During the course of scrutiny assessment proceedings, the Assessing Officer called for stock details as on 31.03.2011 from Punjab National Bank. These details were confronted to the assessee and the assessee was asked to reconcile the discrepancies in the stock position shown to the bank over that reflected in the account books. 4. In its reply, the assessee submitted that quantitative details of finished goods and raw materials as per books of account and bank statement are in agreement. It was explained that the value of stock and spares is given to the bank on estimated basis and it included all items ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... horities. It is the say of the ld. counsel for the assessee that even the Inspection Report of the Senior Manager of Punjab National Bank clearly shows that quantity and value given for the stock and stores agrees with the Borrowers Stock Register and system followed for valuation of stock and spares is as per the terms of sanction. 11. It is the say of the ld. counsel for the assessee that the lower authorities have grossly erred in not understanding the facts in true perspective. The ld. counsel for the assessee stated that though the stock of stores and spares have been given separately to the bank, but the same has been capitalised in the books of account under the head 'Plant and Machinery for Accounting Purposes'. It is the say of th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n the books of account under the head 'Plant and Machinery' as the same were capitalised. 15. We have carefully gone through the financial statements brought on record in the form of paper book. We find force in the contention of the ld. counsel for the assessee. 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. 16. 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 o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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