Bench: : The Hon’Ble Justice T.S. Sivagnanam & The Hon’Ble Justice Hiranmay Bhattacharyya Date : 13Th February, 2023 Appearance : Mr. Ramendra Nath Biswas, Adv. Mr. Avra Mazumdar, Adv. Mr. Suman Bhowmick, Adv. Mr. Samrat Das, Adv. …For The Appellant. Mr. Soumen Bhattacharyya, Adv. …For The Respondent. The Court : This Appeal Filed By The Assessee Under Section 260A Of The Income Tax Act, 1961 (The ‘Act’ For Brevity) Is Directed Against The Order Dated 30Th June, 2009 Passed By The Income Tax Appellate Tribunal, “C” Bench, Kolkata (The Tribunal) In Ita No.151/Kol/2008 For The Assessment Year 1995-96. The Appeal Was Admitted On 23Rd March, 2010 On The Following Substantial Questions Of Law:

Section 133A of the Act. During the course of such survey, stock of inventories was taken in the presence of the assessee-firm and it was found to be of the value of Rs.66,11,036/-. The contention of the assessee was that the goods found in the said shop do not exclusively belong to the assessee but also