Panchsheel Solvent Pvt. Ltd. Vs ACIT (ITAT Raipur)
ITAT Raipur held that change in method of depreciation can be reason for difference in closing stock of plant and machinery in previous year vis-à-vis opening stock in current year and the same needs further examination, hence matter restored back.
Facts- The assessee is a resident company, engaged in the business of manufacturing and trading of edible oil and rice bran oil. The case was selected for limited scrutiny. AO made certain additions on account of discrepancies pointed out in the assessment order are made to the income of the assessee, thus, the total income was enhanced from NIL to Rs.1,14,90,060/-.
CIT(A) dismissed the appeal. Being aggrieved, the present appeal is filed.
Conclusion- Held that necessary supporting documents to substantiate the addition in assets by way of fresh investment are furnished before the Ld. AO, however, the addition was made on account of unexplained investment, whereas referring to the bank statement of the assessee, the source of investment cannot be construed as unexplained at threshold, without considering the entries through banking channel which are claimed to be duly recorded in the books of the assessee. Under such circumstances, it cannot be said that all the evidence laid are ingenuine or bogus and the transactions is totally through unexplained investments. However, it seems that the assessee was unable to explain the source of investment made to the satisfaction of the Ld. AO, which though as per the narrative in the assessment order does not find to be specifically harped upon by the Ld. AO, when the part information was furnished by the assessee. Since the information furnished before us supports the assessee’s contention that the investments are made from explained sources subject to verification of such evidence, thus, it would be fair and justified to restore this issue back to the file of Ld. AO for fresh adjudication in light of the facts on record.
