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ITAT allowed the assessee-firm's appeal substantially. It held that the surrender of excess cash and stock during survey was voluntary, in good faith, duly recorded in the regular books and returns, and fully covered the discrepancies; hence, no further addition was warranted on that account. Additions towards alleged unexplained investment in building construction, based solely on survey statement without any corroborative material or DVO reference, were deleted. The addition of Rs. 1 crore based on impounded slips showing temporary fund movements between the firm and partners was treated as mere circulation of excess liquid funds already covered by the Rs. 40 lakh surrender. Additions of Rs. 80 lakh for sundry debtors and Rs. 5.79 lakh on rejection of book results were also deleted.
ITAT allowed the assessee-firm's appeal substantially. It held that the surrender of excess cash and stock during survey was voluntary, in good faith, duly recorded in the regular books and returns, and fully covered the discrepancies; hence, no further addition was warranted on that account. Additions towards alleged unexplained investment in building construction, based solely on survey statement without any corroborative material or DVO reference, were deleted. The addition of Rs. 1 crore based on impounded slips showing temporary fund movements between the firm and partners was treated as mere circulation of excess liquid funds already covered by the Rs. 40 lakh surrender. Additions of Rs. 80 lakh for sundry debtors and Rs. 5.79 lakh on rejection of book results were also deleted.
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