29. In view of the above discussion, the appeal filed by the assessee deserves to be dismissed
Bench: this Tribunal by way of ITSSA No. 13 & 14/JP/2003. The assessee filed cross-objections i.e. CO No. 20/JP/2003 and CO No. 21/JP/2003. Hon'ble ITAT Tribunal upheld the decision given by Learned CIT(A) regarding deletion of above said two additions. That is how, the Department felt dis-satisfied, and as such preferred D.B. Income Tax Appeal No. 195/2004 before the Hon'ble High Court. 7. Hon'ble High Court, vide order dated 02.11.2016, disposed of the
Sections 32, 40(a)(ia) and 43B etc., which are not on the aspect of any grave substantive tax evasion practices like out of the books stock etc., In this regard, he also relied on the decision in case of Shah Originals v. Commissioner of Income Tax-24, (2023) 156 taxmann.com 695 (SC). Accordingly, Learned CIT(A) disallowed the claim