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    <title>2013 (11) TMI 226 - ITAT AHMEDABAD</title>
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    <description>The Tribunal referred the penalty imposition issue back to the AO for further verification of the assessee&#039;s explanation regarding discrepancies in stock inventory. The Tribunal emphasized the need for the AO to establish the taxpayer&#039;s wrongdoing through investigation rather than solely relying on statements. The penalty proceedings were deemed timely initiated within the statutory period. The Tribunal upheld the quantum addition of excess stock but directed a re-examination of the explanation during penalty proceedings. The Tribunal confirmed the evidentiary value of statements recorded during the survey, emphasizing their relevance in quantum proceedings. The appeal was treated as allowed for statistical purposes.</description>
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      <link>https://www.taxtmi.com/caselaws?id=239049</link>
      <description>The Tribunal referred the penalty imposition issue back to the AO for further verification of the assessee&#039;s explanation regarding discrepancies in stock inventory. The Tribunal emphasized the need for the AO to establish the taxpayer&#039;s wrongdoing through investigation rather than solely relying on statements. The penalty proceedings were deemed timely initiated within the statutory period. The Tribunal upheld the quantum addition of excess stock but directed a re-examination of the explanation during penalty proceedings. The Tribunal confirmed the evidentiary value of statements recorded during the survey, emphasizing their relevance in quantum proceedings. The appeal was treated as allowed for statistical purposes.</description>
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      <pubDate>Fri, 24 May 2013 00:00:00 +0530</pubDate>
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