Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2015 (7) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2015 (7) TMI 1309 - ITAT AGRAUndisclosed income surrendered - addition on account of stock - addition was made solely and wholly on the basis of statement recorded on 16.10.2006 and the surrender made there-under by the assessee - Held that:- CIT(A) has recorded a finding that inventory of stock prepared on the date of survey on 05.10.2006 does not mention the location in which the said raw material has been found and inventorised when the same raw material has already been inventorised at page No. 2 of the list, as reproduced by the CIT(A). CIT(A) has recorded that on 05.10.2007, after receiving copy of stock statement and valuation of stock as on 05.09.2007, the assessee has retracted from the statement made on account of stock vide letter dated 05.10.2007. The account books of the assessee could not be relied upon as the same do not reflect correct state of affairs of the assessee. However, the addition made of ₹ 24,09,475/- was on higher side due to the facts narrated above and the ends of justice shall met if the addition is restricted to ₹ 10,00,000/- by way of estimate and preponderance of probabilities as against ₹ 24,09,475/- made by the AO on account of stock variation found at the time of survey. Ground No. 1 of appeal of the Revenue is partly allowed.
|