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    <title>2018 (6) TMI 1377 - ITAT MUMBAI</title>
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    <description>Survey-based stock discrepancy was not treated as full unexplained income because the material did not establish actual excess stock or suppressed sales outside the books; only the profit element embedded in the disputed stock difference was brought to tax by applying a reasonable gross profit rate. Additions derived from impounded material and alleged decimal manipulation were also not sustained in full, as the extrapolated figure rested on surmises rather than reliable evidence. The large decimal-based addition was deleted, while the remaining connected additions were confined to amounts supported by the cash-flow statement and established profit element, resulting in partial relief and partial sustainment of the connected adjustments.</description>
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      <link>https://www.taxtmi.com/caselaws?id=362550</link>
      <description>Survey-based stock discrepancy was not treated as full unexplained income because the material did not establish actual excess stock or suppressed sales outside the books; only the profit element embedded in the disputed stock difference was brought to tax by applying a reasonable gross profit rate. Additions derived from impounded material and alleged decimal manipulation were also not sustained in full, as the extrapolated figure rested on surmises rather than reliable evidence. The large decimal-based addition was deleted, while the remaining connected additions were confined to amounts supported by the cash-flow statement and established profit element, resulting in partial relief and partial sustainment of the connected adjustments.</description>
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