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    <title>2023 (11) TMI 860 - ITAT DELHI</title>
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    <description>Survey-based additions for alleged excess jewellery stock were rejected where the books and survey records showed combined valuation of mixed items, negligible discrepancies against the total stock, and valuation estimates that could not reliably distinguish purity or embedded diamonds. For 22 kt gold and polki jewellery, the small gram difference was treated as a normal valuation and weighment variance, so the addition was deleted. For 14 kt and 18 kt jewellery, inter-mixing and the absence of clear purity tagging meant the gap was only an estimation variance, not unexplained stock, so the addition was deleted. For studded jewellery, the diamond quantity was derived from gross-weight estimates and was insufficient to support an addition, so that addition was also deleted.</description>
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      <description>Survey-based additions for alleged excess jewellery stock were rejected where the books and survey records showed combined valuation of mixed items, negligible discrepancies against the total stock, and valuation estimates that could not reliably distinguish purity or embedded diamonds. For 22 kt gold and polki jewellery, the small gram difference was treated as a normal valuation and weighment variance, so the addition was deleted. For 14 kt and 18 kt jewellery, inter-mixing and the absence of clear purity tagging meant the gap was only an estimation variance, not unexplained stock, so the addition was deleted. For studded jewellery, the diamond quantity was derived from gross-weight estimates and was insufficient to support an addition, so that addition was also deleted.</description>
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