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ITAT held that additional income declared by assessee during survey u/s 133A relating to unexplained stock should be taxed as business income at normal rates rather than under sections 69/69C read with section 115BBE. The tribunal found that since assessee's sole source of income was retail shoe trading with no other business activities discovered during survey or subsequently, the excess stock constituted business income. Following precedent in Bajargan Traders, ITAT upheld CIT(A)/NFAC order directing assessment officer to treat additional income as normal business income instead of applying penal provisions. Revenue's appeal was dismissed, confirming taxation at regular business income rates rather than higher rates under unexplained investment provisions.
ITAT held that additional income declared by assessee during survey u/s 133A relating to unexplained stock should be taxed as business income at normal rates rather than under sections 69/69C read with section 115BBE. The tribunal found that since assessee's sole source of income was retail shoe trading with no other business activities discovered during survey or subsequently, the excess stock constituted business income. Following precedent in Bajargan Traders, ITAT upheld CIT(A)/NFAC order directing assessment officer to treat additional income as normal business income instead of applying penal provisions. Revenue's appeal was dismissed, confirming taxation at regular business income rates rather than higher rates under unexplained investment provisions.
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