Jaipur Jaipur LFkk;hys[kk la@thvkbZvkj la@PAN/GIR No.: AAACZ 2642 J vihykFkhZ@Appellant izR;FkhZ@Respondent vk;dj vihy la@ITA No. 631/JP/2024 fu/kZkj.k o"kZ@Assessment Year :201516 Zari Silk (India) Pvt. Ltd., cuke Deputy Commissioner of Narayan Singh, Circle, Vs. Income Tax, Jaipur Circle2, Jaipur LFkk;hys[kk la@thvkbZvkj la@PAN/GIR No.: AAACZ 2642 J vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj l@ s Assessee by : Sh. S. R. Sharma, CA & Sh. R. K. Bhatra, CA jktLo dh vksjls@Revenueby: Mrs. Anita Rinesh, JCITSr. DR lquokbZ dh rkjh[k@Date of Hearing : 12/12/2024 mn?kks"k.kk dh rkjh[k@Date of Pronouncement : 09/01/2025 vkns'k@ORDER PER: RATHOD KAMLESH JAYANTBHAI, AM Both the present cross appeals are filed because revenue and assessee feel aggrieved by the order dated 11.03.2024 by the ld. Commissioner of Income Tax 2 ITA Nos. 693 & 631/JP/2024 Zari Silk (India) Pvt. Ltd. (Appeals), Jaipur 5 [ for short CIT(A) ], for the Assessment Year 201516. The said order of the ld. CIT(A) was passed because the assessee challenged before him the assessment order passed by DCIT, Circle2, Jaipur [ for short AO ] u/s 143 (3) of the Income Tax Act, 1961 [ for short "Act"] on 26.12.2017. 2. At the outset of hearing, the Bench observed that there is delay of 05 days in filing of the appeal by the revenue for which the ld. DR representing the revenue relied upon the condonation petition filed by AO vide letter dated 14.05.2024. In that condonation petition ld. AO pleaded that he was busy with additional pressure of work related to pending SLPs to be filed which were over hundred in number. Thus, he could not attend the work of the filling of the appeal in due time. 2.1 On the other hand, ld. AR of the assessee did not raise any objection to the prayer of the ld. AO. 2.2 We have heard rival contentions. As we note that the reasons advanced by the ld. AO in the prayer was that he was under pressure of filling 100 plus SLPs and therefore, he could not attend to the work of filling the present appeal in time. We note that though the appeal is to be filed within 60 days' time and the appeal filed was reasoned to be delayed that 3 ITA Nos. 693 & 631/JP/2024 Zari Silk (India) Pvt. Ltd. the ld. AO was busy. We consider the peculiar facts of the case and condone the delay but at the same time expect that revenue should be vigilant while adhering to the timeline for filling of the appeal. 3. As is evident that the cross appeal relates to one assessee, involving the same assessment year and it deals with the one order of the Assessing Officer as well as one order of ld. CIT(A). We have heard the parties on the same day and by way of this consolidated order proceed to deal both the cross appeals. 3.1 The grounds of appeal taken by the revenue in ITA No. 693/JP/2024 for A.Y 201516 read as under; (i) Whether on the facts and in the circumstances of the case, the Ld. CIT(A) is justified in deleting the addition of Rs. 1,98,88,536/ made on account of value of stock found without appreciating the fact that during the assessment proceedings, the assessee claimed that, wages paid to labour in the Tally was recorded as indirect expense, however, the same is direct expense and therefore, the closing stock will increase by Rs. 1,98,88,536/ and hence added to the total income of the assessee. (ii) Whether on the facts and in the circumstances of the case, the Ld. CIT(A) is justi