VISHWANATH AGGARWAL,DELHI vs. THE ADDL. CIT, CENTRAL RANGE-05, DELHI

The appeals of the assessee are allowed and the penalty is deleted

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

reassessments conducted pursuant to Section 153A.Therefore, even if no additions are made to the income of the Assessee under Section 153A, it does not absolve them from liability under Sections 27ID and 271E if they are found to have contravened the provisions of Sections 269SS and 269T. As such, the penalties prescribed under Sections 27ID and 27IE serve a distinct

VISHWANATH AGGARWAL,DELHI vs. THE ADDL. CIT, CENTRAL RANGE-05, DELHI

The appeals of the assessee are allowed and the penalty is deleted

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

reassessments conducted pursuant to Section 153A.Therefore, even if no additions are made to the income of the Assessee under Section 153A, it does not absolve them from liability under Sections 27ID and 271E if they are found to have contravened the provisions of Sections 269SS and 269T. As such, the penalties prescribed under Sections 27ID and 27IE serve a distinct

VISHWANATH AGGARWAL,DELHI vs. THE ADDL. CIT, CENTRAL RANGE-05, DELHI

The appeals of the assessee are allowed and the penalty is deleted

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

reassessments conducted pursuant to Section 153A.Therefore, even if no additions are made to the income of the Assessee under Section 153A, it does not absolve them from liability under Sections 27ID and 271E if they are found to have contravened the provisions of Sections 269SS and 269T. As such, the penalties prescribed under Sections 27ID and 27IE serve a distinct

VISHWANATH AGGARWAL ,DELHI vs. THE ADDL. CIT, CENTRAL RANGE-05, DELHI

The appeals of the assessee are allowed and the penalty is deleted

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

reassessments conducted pursuant to Section 153A.Therefore, even if no additions are made to the income of the Assessee under Section 153A, it does not absolve them from liability under Sections 27ID and 271E if they are found to have contravened the provisions of Sections 269SS and 269T. As such, the penalties prescribed under Sections 27ID and 27IE serve a distinct

VISHWANATH AGGARWAL,DELHI vs. THE ADDL. CIT, CENTRAL RANGE-05, DELHI

The appeals of the assessee are allowed and the penalty is deleted

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

reassessments conducted pursuant to Section 153A.Therefore, even if no additions are made to the income of the Assessee under Section 153A, it does not absolve them from liability under Sections 27ID and 271E if they are found to have contravened the provisions of Sections 269SS and 269T. As such, the penalties prescribed under Sections 27ID and 27IE serve a distinct

VISHWANATH AGGARWAL,DELHI vs. THE ADDL. CIT, CENTRAL RANGE-05, DELHI

The appeals of the assessee are allowed and the penalty is deleted

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

reassessments conducted pursuant to Section 153A.Therefore, even if no additions are made to the income of the Assessee under Section 153A, it does not absolve them from liability under Sections 27ID and 271E if they are found to have contravened the provisions of Sections 269SS and 269T. As such, the penalties prescribed under Sections 27ID and 27IE serve a distinct

VISHWANATH AGGARWAL,DELHI vs. THE ADDL. CIT, CENTRAL RANGE-05, DELHI

The appeals of the assessee are allowed and the penalty is deleted

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

reassessments conducted pursuant to Section 153A.Therefore, even if no additions are made to the income of the Assessee under Section 153A, it does not absolve them from liability under Sections 27ID and 271E if they are found to have contravened the provisions of Sections 269SS and 269T. As such, the penalties prescribed under Sections 27ID and 27IE serve a distinct

VISHWANATH AGGARWAL ,DELHI vs. THE ADDL. CIT, CENTRAL RANGE-05, DELHI

The appeals of the assessee are allowed and the penalty is deleted

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

reassessments conducted pursuant to Section 153A.Therefore, even if no additions are made to the income of the Assessee under Section 153A, it does not absolve them from liability under Sections 27ID and 271E if they are found to have contravened the provisions of Sections 269SS and 269T. As such, the penalties prescribed under Sections 27ID and 27IE serve a distinct

YOGENDER MOHAN RUSTAGI,DELHI vs. ACIT, CENTRAL CIRCLE 28, DELHI

In the result, the appeal of the assessee is allowed

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2017-18 Yogender Mohan Rustagi Vs Acit Central Circle -28 548/549 Katra Ishwar Bhawan Delhi Khari Baoli Delhi-110006 Pan No. Agupr9629J (Appellant) (Respondent)

275 of the Act shall, so far as may be, apply. Sub Section (1) of Section 274 of the Act mandates that order imposing penalty has to be imposed only after hearing the assessee or giving a assessee opportunity of hearing. Opportunity that is to be given to the assessee should be a meaningful one and not a farce. Notice

THE COMMISSIONER OF INCOME TAX-V vs. ORIENT CRAFT LTD

c) of Explanation 2 below Section 147, which provides that claiming excessive deduction would amount to a case of income escaping assessment. He thus rejected the assessee‟s objection. On merits he held that the assessee was not entitled to any deduction under Section 80HHC in respect of the premium on sale of quota. He also held that the assessee

CHIRANJEEV KUMAR VINAYAK,NEW DELHI vs. ITO, WARD-47(5), NEW DELHI

In the result, assessee’s appeal is dismissed

Bench: Shri Kul Bharat

reassessment or rectification proceedings, but not penalty proceedings. (iii) If ingredients contained in (i) and (ii) are present a notice to show cause under Section 274 of the Act shall issue setting out therein the infraction the assessee is said to have committed. The notice under Section 274 of the Act can be issued both during or after the completion

HINDUSTAN COCA-COLA BEVERAGES CO. P.LTD,GURUGRAM vs. JCIT, RANGE-74, NEW DELHI

Accordingly, the stay application is dismissed as

Bench: Shri Shamim Yahya & Ms. Astha Chandraआ.अ.सं/.I.T.A No.3018/Del/2022 िनधा"रणवष"/Assessment Year: 2005-06 बनाम Hindustan Coca-Cola Beverages Jcit Vs. Co. P. Ltd., Range-74, Unit No. 303-304, 3Rd Floor, New Delhi. Baani Address One, Golf Course Road, Sector-56, Gurgaon, Haryana. Pan No. Aaach3005M अपीलाथ" Appellant ""यथ"/Respondent & Stay Appl. No.413/Del/2022 िनधा"रणवष"/Assessment Year: 2005-06 बनाम Hindustan Coca-Cola Beverages Jcit Co. P. Ltd., Vs. Range-74, Unit No. 303-304, 3Rd Floor, New Delhi. Baani Address One, Golf Course Road, Sector-56, Gurgaon, Haryana. Pan No. Aaach3005M अपीलाथ" Appellant ""यथ"/Respondent

section 275 of the Act. He further referred to several case laws in this regard. The proposition canvassed by the learned AR summarized as under: “Proposition: 1) Penalty proceedings have been initiated belatedly after reasonable period of 4/6 years a) The limitation for reassessment at relevant time was 6 years b) Limitation for 201 proceedings is 7 years I.T.A.No.3018/Del/2022

M/S. JAY BHARAT MARUTI LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal is allowed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2005-06 & Assessment Year: 2006-07 Acit, Vs. M/S. Jay Bharat Maruti Ltd., Circle-4(1), 601, Hemkunt Chamber, New Delhi 89-Nehru Place, New Delhi Pan :Aaacj2021K (Appellant) (Respondent) & C.O. No.113/Del/2012 [Arising Out Of Ita No.908/Del/2012] Assessment Year: 2005-06 & C.O. No.114/Del/2012 [Arising Out Of Ita No.909/Del/2012] Assessment Year: 2006-07 M/S. Jay Bharat Maruti Ltd., Vs. Acit, 601, Hemkunt Chamber, Circle-4(1), 89-Nehru Place, New Delhi New Delhi Pan :Aaacj2021K (Appellant) (Respondent) & Assessment Year: 2005-06 M/S. Jay Bharat Maruti Ltd., Vs. Acit, Neel House, Lado Sarai, Circle-4(1), Opp. Qutab Minar, Mehrauli, New Delhi New Delhi Pan :Aaacj2021K (Appellant) (Respondent)

reassessment proceeding, the Assessing Officer issued a show-cause notice to the assessee to explain, why the deduction claimed towards payment of lease rent amounting to Rs.6,68,43,636/- to State Bank of India should not be disallowed. In response to the show-cause notice, the assessee submitted that the lease rent of Rs.19,28,97,000/- debited

DCIT, NEW DELHI vs. M/S. JAY BHARAT MARUTI LTD., NEW DELHI

In the result, the appeal is allowed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2005-06 & Assessment Year: 2006-07 Acit, Vs. M/S. Jay Bharat Maruti Ltd., Circle-4(1), 601, Hemkunt Chamber, New Delhi 89-Nehru Place, New Delhi Pan :Aaacj2021K (Appellant) (Respondent) & C.O. No.113/Del/2012 [Arising Out Of Ita No.908/Del/2012] Assessment Year: 2005-06 & C.O. No.114/Del/2012 [Arising Out Of Ita No.909/Del/2012] Assessment Year: 2006-07 M/S. Jay Bharat Maruti Ltd., Vs. Acit, 601, Hemkunt Chamber, Circle-4(1), 89-Nehru Place, New Delhi New Delhi Pan :Aaacj2021K (Appellant) (Respondent) & Assessment Year: 2005-06 M/S. Jay Bharat Maruti Ltd., Vs. Acit, Neel House, Lado Sarai, Circle-4(1), Opp. Qutab Minar, Mehrauli, New Delhi New Delhi Pan :Aaacj2021K (Appellant) (Respondent)

reassessment proceeding, the Assessing Officer issued a show-cause notice to the assessee to explain, why the deduction claimed towards payment of lease rent amounting to Rs.6,68,43,636/- to State Bank of India should not be disallowed. In response to the show-cause notice, the assessee submitted that the lease rent of Rs.19,28,97,000/- debited

M/S. JAY BHARAT MARUTI LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal is allowed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2005-06 & Assessment Year: 2006-07 Acit, Vs. M/S. Jay Bharat Maruti Ltd., Circle-4(1), 601, Hemkunt Chamber, New Delhi 89-Nehru Place, New Delhi Pan :Aaacj2021K (Appellant) (Respondent) & C.O. No.113/Del/2012 [Arising Out Of Ita No.908/Del/2012] Assessment Year: 2005-06 & C.O. No.114/Del/2012 [Arising Out Of Ita No.909/Del/2012] Assessment Year: 2006-07 M/S. Jay Bharat Maruti Ltd., Vs. Acit, 601, Hemkunt Chamber, Circle-4(1), 89-Nehru Place, New Delhi New Delhi Pan :Aaacj2021K (Appellant) (Respondent) & Assessment Year: 2005-06 M/S. Jay Bharat Maruti Ltd., Vs. Acit, Neel House, Lado Sarai, Circle-4(1), Opp. Qutab Minar, Mehrauli, New Delhi New Delhi Pan :Aaacj2021K (Appellant) (Respondent)

reassessment proceeding, the Assessing Officer issued a show-cause notice to the assessee to explain, why the deduction claimed towards payment of lease rent amounting to Rs.6,68,43,636/- to State Bank of India should not be disallowed. In response to the show-cause notice, the assessee submitted that the lease rent of Rs.19,28,97,000/- debited

ACIT, NEW DELHI vs. M/S. JAY BHARAT MARUTI LTD., NEW DELHI

In the result, the appeal is allowed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2005-06 & Assessment Year: 2006-07 Acit, Vs. M/S. Jay Bharat Maruti Ltd., Circle-4(1), 601, Hemkunt Chamber, New Delhi 89-Nehru Place, New Delhi Pan :Aaacj2021K (Appellant) (Respondent) & C.O. No.113/Del/2012 [Arising Out Of Ita No.908/Del/2012] Assessment Year: 2005-06 & C.O. No.114/Del/2012 [Arising Out Of Ita No.909/Del/2012] Assessment Year: 2006-07 M/S. Jay Bharat Maruti Ltd., Vs. Acit, 601, Hemkunt Chamber, Circle-4(1), 89-Nehru Place, New Delhi New Delhi Pan :Aaacj2021K (Appellant) (Respondent) & Assessment Year: 2005-06 M/S. Jay Bharat Maruti Ltd., Vs. Acit, Neel House, Lado Sarai, Circle-4(1), Opp. Qutab Minar, Mehrauli, New Delhi New Delhi Pan :Aaacj2021K (Appellant) (Respondent)

reassessment proceeding, the Assessing Officer issued a show-cause notice to the assessee to explain, why the deduction claimed towards payment of lease rent amounting to Rs.6,68,43,636/- to State Bank of India should not be disallowed. In response to the show-cause notice, the assessee submitted that the lease rent of Rs.19,28,97,000/- debited

ACIT, NEW DELHI vs. M/S. JAY BHARAT MARUTI LTD., NEW DELHI

In the result, the appeal is allowed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2005-06 & Assessment Year: 2006-07 Acit, Vs. M/S. Jay Bharat Maruti Ltd., Circle-4(1), 601, Hemkunt Chamber, New Delhi 89-Nehru Place, New Delhi Pan :Aaacj2021K (Appellant) (Respondent) & C.O. No.113/Del/2012 [Arising Out Of Ita No.908/Del/2012] Assessment Year: 2005-06 & C.O. No.114/Del/2012 [Arising Out Of Ita No.909/Del/2012] Assessment Year: 2006-07 M/S. Jay Bharat Maruti Ltd., Vs. Acit, 601, Hemkunt Chamber, Circle-4(1), 89-Nehru Place, New Delhi New Delhi Pan :Aaacj2021K (Appellant) (Respondent) & Assessment Year: 2005-06 M/S. Jay Bharat Maruti Ltd., Vs. Acit, Neel House, Lado Sarai, Circle-4(1), Opp. Qutab Minar, Mehrauli, New Delhi New Delhi Pan :Aaacj2021K (Appellant) (Respondent)

reassessment proceeding, the Assessing Officer issued a show-cause notice to the assessee to explain, why the deduction claimed towards payment of lease rent amounting to Rs.6,68,43,636/- to State Bank of India should not be disallowed. In response to the show-cause notice, the assessee submitted that the lease rent of Rs.19,28,97,000/- debited

DEFSYS SOLUTIONS P.LTD,NEW DELHI vs. ACIT, CENTRAL CIRCLE-15, NEW DELHI

In the result the appeal of the assessee in ITA No

Bench: Shri N.K. Billaiya & Ms Astha Chandra

reassessments (uls 143(3),147, 153A, 153C rectificationl appellate orderl revisions etc. Add: Addition as per recommendation of TPO uls 11,27,15,4101- 92CA -" Add: Addition as per issue of ~ 12,175/- Disallowance Add: Addition on account of excess physical 14,28,834/- stock Add: Addition on account of less physical ~~~ 20,00,9801- stock Add: Addition on account