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• The above argument of the appellant in respect of totaling mistake of Rs 10,66, 150/- is found to be correct and acceptable.

• Other Difference • The appellant had argued that the remaining insignificant amount of Rs. 375,913/- deserves to be ignored having regard to possibility of human error, voluminous nature of the inventory and estimations adopted by the department. • The argument of the appellant is not acceptable as all the possible human error had already been considered • Thus, the arguments for difference of Rs 3,75,913/- is not acceptable.

44. Thus, there was difference of Rs 1,066,150 (Rs. 9651418 minus 85,85,268/-) on account of totaling mistake/omission as explained above, which is apparent from the stock sheet summary prepared by the survey authorities available at page no. 19 of PB. The remaining insignificant amount of Rs.375,913/- deserves to be ignored having regard to possibility of human error, voluminous nature of the inventory and estimations adopted by the department.

45. In view of the above, it is evident that the impugned valuation of the stock done by department was not correct as the same was based on eye estimation also. Therefore, the addition of Rs.14,42,063/- deserves to be deleted.