- (1.) Leave granted. The instant matter arises out of an application under Section 154 of the Income Tax Act, 1961 seeking rectification of the return of income for Assessment Year 1996-1997.
(2.) Vide order dated 27-2-1998 the assessing officer made an addition of Rs. 9,77,529 to the value of the closing stock and as a result the total income of the assessee stood increased from Rs. 3,40,526 to Rs. 13,18,055. The assessee opted for the Kar Vivad Samadhan Scheme, 1998 (KVSS) and paid the tax payable on the basis of the increased income amounting to Rs. 13,18,055 for Assessment Year 1995-1996. Accordingly, the assessee herein moved an application under Section 154 of the Income Tax Act requesting the assessing officer to give consequential effect to the order passed on 27-2-1998.
(3.) The assessing officer rejected the application on the ground that the assessee had suppressed the work-in-progress undertaken by the appellant (assessee) in respect of Shri G.K. Badola and Shri Rajinder Behl. Consequentially, the rectification application filed by the assessee came to be rejected. This order was upheld by the Commissioner of Income Tax (Appeals) and the High Court vide the impugned judgment (overruling the order passed by the Tribunal) upholding the allegation of suppression.;