https://www.taxtmi.com/caselaws?id=449063 The ITAT Delhi dismissed the Revenue's appeal regarding excess stock assessment under section 69A. The Survey Team calculated excess stock by applying a 25.74% gross profit rate instead of the accepted 24.16% rate from the return, without physical verification or incriminating evidence. The CIT(A) correctly found this arbitrary stock revaluation improper. For section 69A additions, specific evidence of ownership of unexplained valuable articles is required, with clear identification that stock has no business nexus. Without physical verification and proper evidence, the excess stock addition was unjustified. en-us Thu, 14 Dec 2023 00:00:00 +0530 Mon, 05 Feb 2024 08:44:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449063 The ITAT Delhi dismissed the Revenue's appeal regarding excess stock assessment under section 69A. The Survey Team calculated excess stock by applying a 25.74% gross profit rate instead of the accepted 24.16% rate from the return, without physical verification or incriminating evidence. The CIT(A) correctly found this arbitrary stock revaluation improper. For section 69A additions, specific evidence of ownership of unexplained valuable articles is required, with clear identification that stock has no business nexus. Without physical verification and proper evidence, the excess stock addition was unjustified. Case-Laws Income Tax Thu, 14 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449063