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2013 (6) TMI 546 - ITAT KOLKATASuppressed purchase - addition on account on account closing stock - Held that:- Contention of the assessee is justified more so because it is not the case of the AO to have found involvement of the assessee in trying to hold separate books of accounts for the purpose of support at the time of the assessment before the AO when a survey has been conducted after the end of the financial year and the soft copy of the financial statements which were yet to be audited and verified by the auditor were to be held u/s 292C. It is the usual practice that the accounts which are maintained on the computer are subject to audit and the basic mistakes or errors committed by the accountant are to be rectified on the objections of the audit team which are rectified may or may not be corrected in the soft copy, in so far as, the hard copies generated of the surveyed e-filing of the return which figures cannot be disturbed as a matter of suppression or willful declaration for undisclosed income has been considered by the authorities below on presumption only. No so called additions as raised by the assessee appellant in the grounds above would stand to nullity in so far as they stood corrected to the extent that their reconciliation would determine the excess income rendered by the assessee were reconciliation to the additions and disallowances made by the AO and complied with as per provisions of Section 44AB r.w.s. 145(1) and 145(2). This arithmetical accuracy lead to finalization of accounts which has not been challenged by the AO and the CIT(A) & thus inclined to hold that the survey operation impounding the CD under the provision of section 292C was to be addressed for accuracy under the accounting system accepted by him u/s 44AB. The additions so made by the AO are directed to be deleted - in favour of assessee.
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