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Section 69 of the Income-tax Act, 1961 - Unexplained investments Where there was difference between value of stock shown in accounts and value disclosed to bank, and Tribunal's finding was that Assessing Officer had not been able to point out any discrepancy in quantity of stock hypothecated to bank and quantity of stock as per books of account, on face of such finding, even if there was some difference in valuation of stock as mentioned above, it could not be said to be resulting into any income from undisclosed sources, coming to assessee, capable of being added to its income. [In favour of assessee] . CIT v. Laxmi Engineering Industries [2009] 308 ITR 279 (Raj) There can be circumstances where there may be difference in the quantity of stock, as appearing in the balance-sheet, and as appearing in the hypothecation made to the bank, and if there is any explanation coming forward for the discrepancy, then the addition need not be made, and that, sufficiency or reliability of the explanation, offered by the assessee, is a question of fact, and the findings thereon, as recorded by Tribunal, cannot be interfered with by the High Court, as it does not give rise to any substantial question of law. Where there was difference between the value of stock shown in accounts and the value disclosed to the bank, and the Tribunal's finding was that the Assessing Officer had not been able to point out any discrepancy in the quantity of stock hypothecated to the bank and the quantity of stock as per books of account, on the face of such finding, even if there was some difference in the valuation of the said quantity of the stock in the balance-sheet, as against the valuation shown in the bank, it could not be said to be resulting into any income from undisclosed sources, coming to the assessee, capable of being added to its income. K.K Bissa for the Appellant. Sanjeev Johari for the Respondent. JUDGMENT 1. These three appeals arise out of the common judgment of the learned Tribunal dated July 14, 2003. The appeals relate to different assessment years, with respect to the same assessee, and have been filed by the Revenue, involving common question, and, therefore, are being…

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