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The ITAT allowed the appellant's appeal, deleting three additions made by the AO. Regarding unexplained cash under s.69A, the Tribunal held that a statement made during search, though important evidence, is not conclusive and can be retracted. For the silver jewelry addition, the Bench found the AO failed to make proper inquiries despite documentary evidence of approval stock being available. Concerning the alleged excess 18-carat gold jewelry and shortage of 22-carat items, ITAT determined this discrepancy resulted from improper segregation during valuation when tags became jumbled. The negligible weight difference between book records and physical inventory, supported by day-to-day stock registers, justified deletion of these additions.
The ITAT allowed the appellant's appeal, deleting three additions made by the AO. Regarding unexplained cash under s.69A, the Tribunal held that a statement made during search, though important evidence, is not conclusive and can be retracted. For the silver jewelry addition, the Bench found the AO failed to make proper inquiries despite documentary evidence of approval stock being available. Concerning the alleged excess 18-carat gold jewelry and shortage of 22-carat items, ITAT determined this discrepancy resulted from improper segregation during valuation when tags became jumbled. The negligible weight difference between book records and physical inventory, supported by day-to-day stock registers, justified deletion of these additions.
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