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Addition for alleged shortfall between income admitted during search under s.132(4) and income returned under s.153C was examined in light of the assessee's bifurcated disclosure under two heads: estimated real estate business income and income for discrepancies in gross receipts/expenses. The AO taxed only the latter and ignored the estimated real estate component. On aggregating both disclosed heads, the total additional income exceeded the search disclosure, thereby explaining the alleged difference. As the lower authorities sustained the addition without appreciating this reconciliation, the addition of Rs. 8,82,278 was directed to be deleted and the appeal was allowed. - ITAT
Addition for alleged shortfall between income admitted during search under s.132(4) and income returned under s.153C was examined in light of the assessee's bifurcated disclosure under two heads: estimated real estate business income and income for discrepancies in gross receipts/expenses. The AO taxed only the latter and ignored the estimated real estate component. On aggregating both disclosed heads, the total additional income exceeded the search disclosure, thereby explaining the alleged difference. As the lower authorities sustained the addition without appreciating this reconciliation, the addition of Rs. 8,82,278 was directed to be deleted and the appeal was allowed. - ITAT
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