(1.) HEARD learned counsel for the appellant as well as standing counsel appearing for the respondent.
(2.) IT is not in dispute that the entire issue pertains to a search conducted in the premises of the present assessee. The assessment year in question pertains to 2008 -09. The search was carried at the business premises of the assessee on 12 -9 -2007 wherein inventory of the stock was taken note of by the searching officials. Subsequently, during the assessment proceedings, the value of the stock came to be computed by the assessing officer taking into consideration the stock noted during the course of search on the basis of purchase and sales figures adopting a particular rate of gross profit.
(3.) AS a matter of fact, at internal p. 2 of the assessment order, the opening stock as on 1 -4 -2007 found in the records was taken into consideration and cost of the purchases upto the date of search, i.e. 11 -9 -2007 was added. Again, the amount shown as actual sales was deducted so also the gross profit at 6.28 per cent came to be deducted. With all these deductions value of the stock arrived at was Rs. 27,13,818. During the course of search the valuation of the stock taken as on 12 -9 -2007 was Rs. 35,01,679. Thereby the difference of the valuation of the stock was taken as Rs. 7,87,861.