Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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The ITAT upheld the ld.CIT(A)'s decision to treat the excess stock found during the survey as business income, dismissing the revenue's appeal. The AO failed to produce cogent evidence of income from sources other than the jewellery business. The tribunal accepted the assessee's explanation regarding the separate ledger for old gold purchases, increasing the book stock and reducing the excess stock to 11,390.212 grams. The addition was restricted accordingly. Regarding valuation, the tribunal rejected the AO and ld.CIT(A)'s higher rate of Rs. 2,800 per gram and the assessee's lower rate of Rs. 2,296 per gram, adopting Rs. 2,409 per gram as agreed by the assessee in correspondence, to compute income from excess stock. This approach balanced the competing valuations and concluded the matter.
The ITAT upheld the ld.CIT(A)'s decision to treat the excess stock found during the survey as business income, dismissing the revenue's appeal. The AO failed to produce cogent evidence of income from sources other than the jewellery business. The tribunal accepted the assessee's explanation regarding the separate ledger for old gold purchases, increasing the book stock and reducing the excess stock to 11,390.212 grams. The addition was restricted accordingly. Regarding valuation, the tribunal rejected the AO and ld.CIT(A)'s higher rate of Rs. 2,800 per gram and the assessee's lower rate of Rs. 2,296 per gram, adopting Rs. 2,409 per gram as agreed by the assessee in correspondence, to compute income from excess stock. This approach balanced the competing valuations and concluded the matter.
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