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2024 (1) TMI 362 - GUJARAT HIGH COURTAdmission of income made by the assessee at the time of survey - suppression of value of closing stock - unaccounted stock of gold and silver ornaments - HELD THAT:- It is not in dispute that the assessee did not include the difference in the return of income filed by the assessee and merely declared the gold and silver ornaments in survey proceedings in subsequent assessment year was rightly not held that there was no excess stock or unaccounted stock available during the assessment year under consideration. Even the Tribunal perused the document shown on the time of hearing on 11.04.2022 and observed that the assessee could not give any bifurcation as to how much was the quantity sold on the particular period related to the gold ornaments and silver ornaments which shows that the assessee deliberately not bifurcated the unaccounted stock and the regular stock during the period from the date of survey till 31st March, 2015 and accordingly, the Tribunal upheld the finding arrived at by the CIT (Appeals). No infirmity in the concurrent findings of fact arrived at by the CIT (Appeals) as well as the Tribunal while upholding the order passed by the Assessing Officer for making addition on account of the admission made by the assessee at the time of survey with regard to the unaccounted stock of gold and silver ornaments and therefore - no substantial question of law - Asessee appeal is dismissed.
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