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4. i) The appellant filed stock statement before the bank on31.03.2009
and the stock as declared in the stock statement did not tally with
the stock as per books. The AO confronted this fact to the appellant
during the course of assessment proceedings and the appellant
stated during the course of assessment proceeding s that the bank
does not attach much significance to the stock statement and also no
CO. No. 48 & 49(Asr)/2014
physical verification of the stock is carried out because the interest
of the bank is covered by the collateral securities provided by the
appellant to the ban. The A/R of the appellant has also relied on the
fact that the stock statement as on 31.03.2009 on which the AO has
relied and on the basis of which addition has been made, is
unsigned. But the AO did not accept this plea on the basis of
statement of bank manager recorded in the case of Munish Kumar
Bansal Contractor as the bank manager stated in that case that the
stock are physically verified by the bank.