Excess Stock cannot be treated as Treated as unexplained investment without Evidence of Unexplained Sources

Sadanand Bhavan Vs ITO (ITAT Panaji) The appeal before the Income Tax Appellate Tribunal arose from an order passed by the Commissioner of Income Tax (Appeals)-2, Panaji, sustaining additions made by the Assessing Officer under Sections 143(3), 263, and 250 of the Income Tax Act. The assessee, a partnership firm engaged in manufacturing and sale of sweets, had filed its return of income for Assessment Year 2013–14 declaring total income of Rs. 14,64,500. The case was selected for scrutiny, and during prior survey proceedings under Section 133A, excess cash, excess stock, and expenditure on r...