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The High Court held that no question of law arose for reference. The Court found that the ITAT's finding that the value of stock as disclosed in the assessee's books of account was correct was not perverse. The AO and CIT(A) had made and upheld additions solely based on a discrepancy between the book stock and the stock declared to the bank. Once the ITAT accepted the book value of stock as correct, no objection could be raised to the deletions. Consequently, the further inference regarding the correctness of the value of rolls purchased on March 28, 1988, was also rightly held to be not called for. The Court observed that the ITAT's finding was based on the assessee's explanation, the regularity of its accounts, and its compliance with excise reporting, which were not shown to be erroneous. Therefore, the application for reference was dismissed.
