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ITAT upheld the CIT(A)'s deletions of additions relating to "Ghat" receipts and making charges for AYs 2017-18 to 2021-22, concluding the AO's metal-receipt assumption was factually unsustainable and J-Pack entries represented alloy additions and legitimate making charges. The Tribunal deleted additions attributable to receipts accounted in books, but confirmed additions of Rs. 12,13,66,358 and Rs. 1,45,54,166 in respect of byaj and vatav where attribution to the assessee was sustained. The Tribunal rejected further reductions in estimated unaccounted sales but excluded amounts already taxed in an individual's hands to avoid double taxation. Applying telescoping, ITAT allowed set-off of assessed unaccounted income of Rs. 86,15,72,422 against unexplained assets, directing deletion of separate additions for excess stock, cash, receivables and silver.
ITAT upheld the CIT(A)'s deletions of additions relating to "Ghat" receipts and making charges for AYs 2017-18 to 2021-22, concluding the AO's metal-receipt assumption was factually unsustainable and J-Pack entries represented alloy additions and legitimate making charges. The Tribunal deleted additions attributable to receipts accounted in books, but confirmed additions of Rs. 12,13,66,358 and Rs. 1,45,54,166 in respect of byaj and vatav where attribution to the assessee was sustained. The Tribunal rejected further reductions in estimated unaccounted sales but excluded amounts already taxed in an individual's hands to avoid double taxation. Applying telescoping, ITAT allowed set-off of assessed unaccounted income of Rs. 86,15,72,422 against unexplained assets, directing deletion of separate additions for excess stock, cash, receivables and silver.
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