Aggrieved by the AO's order, the assessee appealed to the Commissioner of Income Tax (Appeals) [CIT(A)]. Regarding the stock, the assessee claimed that the Rs. 68,07,172 pertained to his other business, M/s Ram Roop Enterprises (a builder), and was spent on activities like fencing and road construction in FY 2011-12, appearing as closing stock as on 31.03.2012. The CIT(A) found the explanation unconvincing, as the accounts of M/s Ram Roop Enterprises were unaudited, and the Income Tax Return (ITR) for AY 2012-13 showed a closing stock of Nil. The CIT(A) confirmed the addition of Rs. 68,07,172 as unexplained investment under Section 69 of the Income Tax Act. Aggrieved by the CIT(A)'s order, the assessee appealed to the ITAT. The assessee submitted a paper book and relied on case laws, including PCIT vs. Asian Agency. The assessee contended that the AO and CIT(A) erred in treating the opening stock as unaccounted.