Excess stock found during search cannot be the sole reason for rejection of books of accounts

Brief Facts of the case- This appeal has been filed by the revenue. Assessments for four years 2002-03 to 2005-06 were made on 29.12.2006 under Section 153A pursuant to a search conducted on 07.10.2004. The assessee used to procure and restore rice after due processing. In the course of such procurement, it was contended to retain gunny bags supplied by the Food Corporation of India (FCI) and deal with them. After the search and during the assessment proceedings, the assessee had surrendered a sum of ₹1.75 Crores. Apparently, in the course of search, some excess stocks were found. The AO re...