The assessee recorded all imports in its books, but the AO...

The assessee recorded all imports in its books, but the AO presumed non-declaration based on the export-import summary data without considering credit notes. The duty paid matched, and the difference was in the gross assessable value, not the actual cost. The AO made an addition without proper verification, rejecting the assessee's explanation. Even though there was a difference in reconciling the gross assessable value, it did not lead to non-disclosure of income. The Tribunal held that the AO failed to substantiate how recording imports would result in undervaluation or suppression of income. Therefore, the issue was decided in favor of the assessee as there was no involvement of undisclosed income.