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4. Let us take the assessee's appeal in respect of ay 2012-13 first :

4.1 The AR submitted that the CIT(A) erred in sustaining the addition based on the original return overlooking the valid revised return filed by the assessee without assigning proper reason and justification. He submitted that the entire sales representing deficit stock cannot be assessed as such as income and at best the profit embedded in such sales alone should be assessed. He has submitted that the survey statements had no sanctity in the eyes of the law especially in the absence of impounded materials and hence he pleaded that the addition sustained by the CIT(A) be deleted and suggested to direct a reasonable % of the impugned sales as income of this ay. Per contra, the DR invited our attention to the following portion of the statement recorded on Oath at the time of survey which was extracted by the CIT(A).
Q 45: Do you wish to state anything further?
Ans; I wish to state that I will extend my full Co-operation with the department and ensure tax compliance in future. "

It is crystal clear from the fore-going, that on account of glaring lacunae in the maintenance of books especially the fact of unrecorded purchases as well as sales, accumulation of stock over the years, which is on account of unrecorded sales, etc., the assessee cannot justify his claim of set off of any expenditure whatsoever from the amount of admission made by him in the course of survey proceedings. Thus, the question of 'estimating' profit based on deficit stock does not arise at all." and submitted that after the survey the assessee filed return of income for ay 2012-13 on 30.09.2012 admitting total income of Rs. 1,31,69,420/- which included the income admitted at the time of survey. This return was supported by a tax audit certificate. The assessee filed a revised return on 29.03.2014 in which the income is estimated at a mere 5% of stock shortage. The revised return is not supported by any tax audit report. A valid revised return can be filed when the assessee subsequently discovers any inadvertent :-8-: ITA Nos. 216 TO 220 & 112/Chny/2017 omission or error or mistake in-computation. However, the revised return is not supported by any tax audit report and hence, the AO has correctly held that it is filed by an afterthought and rejected the assessee's claim. The CIT(A) has also held that the retraction is made without any basis. The assessee's plea that the sworn statements recorded at the time of survey had no sanctity in the eyes of law is not applicable to the facts of this case where the survey has resulted in a finding of shortage of stock and all other defects and other information's are brought on record. The DR further said that even on merit the assessee's plea is not correct when the assessee has admitted that its purchases were also not accounted and the assessee has not placed any evidence to prove that all his purchases are accounted. In such facts and circumstances, the net profit addition is warranted and hence the addition sustained by the CIT(A) may be upheld.