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    <title>2023 (11) TMI 1093 - ITAT RAJKOT</title>
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    <description>ITAT Rajkot held that excess stock found during survey constituted undisclosed business income rather than deemed income under Section 69A. The tribunal affirmed CIT(A)&#039;s decision allowing deduction of interest and salary paid to partners against surrendered income. Following Fashion World precedent, ITAT ruled that excess stock lacks independent identity as a separate asset since it cannot be physically distinguished from accounted stock. The difference represents mathematical value expression, not identifiable undisclosed investment. Since assessee disclosed purchases in business books and VAT returns, demonstrating business connection, the income was properly characterized as undisclosed business receipts eligible for business deductions.</description>
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    <pubDate>Wed, 05 Jul 2023 00:00:00 +0530</pubDate>
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      <title>2023 (11) TMI 1093 - ITAT RAJKOT</title>
      <link>https://www.taxtmi.com/caselaws?id=446202</link>
      <description>ITAT Rajkot held that excess stock found during survey constituted undisclosed business income rather than deemed income under Section 69A. The tribunal affirmed CIT(A)&#039;s decision allowing deduction of interest and salary paid to partners against surrendered income. Following Fashion World precedent, ITAT ruled that excess stock lacks independent identity as a separate asset since it cannot be physically distinguished from accounted stock. The difference represents mathematical value expression, not identifiable undisclosed investment. Since assessee disclosed purchases in business books and VAT returns, demonstrating business connection, the income was properly characterized as undisclosed business receipts eligible for business deductions.</description>
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      <pubDate>Wed, 05 Jul 2023 00:00:00 +0530</pubDate>
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