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Judgment
S. Ravindra Bhat, J
The appellant has filed this appeal under Section 260A of the Income Tax Act, 1961 (hereafter referred to as ‘the Act’). The question for
consideration of the Income Tax Appellate Tribunal (ITAT) was that a sum of  Rs. 8,67,87,925/- was added in the course of search assessment
conducted in the case of M/s Gee Ispat Group of companies. The search of those companies took place on 07.01.2010 for A.Y. 2010-11, was
completed under Section 143(3) of the Act and substantial additions were made.
The assessee â€" sole proprietor of M/s Deshraj Ashutosh involved in the business of sale and purchase of foodgrains on commission basis, was
saddled with petitioner’s liability on account of difference and discrepancy in the stock. The AO was of the opinion that an addition of  Rs.
8,67,87,925/- was justified on account of the discrepancy. The Appellate Commissioner was satisfied with the assessee’s explanation with respect
to inflated statement of stock with the bankers and noted that no discrepancy in the stock statements as appearing from the physical verification and
that apparent from the books of account emerged. The amount was, therefore, deleted. The ITAT upheld the findings of the CIT(A).
This Court is of the opinion that having regard to the concurrent findings of fact, no substantial question of law arises as the issues pertain to pure
appreciation of facts.
The appeal is, therefore, dismissed.