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    <title>2021 (9) TMI 1560 - ITAT RAIPUR</title>
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    <description>The ITAT Raipur allowed the assessee&#039;s appeal against PCIT&#039;s revision order u/s 263. The tribunal held that AO&#039;s assessment treating excess stock as business income rather than unexplained investment u/s 69 was not erroneous, as the assessee consistently declared it as business income from survey proceedings through return filing. The AO had specifically examined this issue and accepted the assessee&#039;s explanation after due application of mind. The tribunal noted judicial precedents supporting taxation of surrendered business income under normal rates rather than u/s 115BBE. Regarding purchase figure mismatches between trial balance and audited balance sheet, the tribunal found the assessee&#039;s explanation of regrouping entries justified and held PCIT&#039;s direction for further enquiry was unwarranted.</description>
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    <pubDate>Wed, 29 Sep 2021 00:00:00 +0530</pubDate>
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      <title>2021 (9) TMI 1560 - ITAT RAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=458119</link>
      <description>The ITAT Raipur allowed the assessee&#039;s appeal against PCIT&#039;s revision order u/s 263. The tribunal held that AO&#039;s assessment treating excess stock as business income rather than unexplained investment u/s 69 was not erroneous, as the assessee consistently declared it as business income from survey proceedings through return filing. The AO had specifically examined this issue and accepted the assessee&#039;s explanation after due application of mind. The tribunal noted judicial precedents supporting taxation of surrendered business income under normal rates rather than u/s 115BBE. Regarding purchase figure mismatches between trial balance and audited balance sheet, the tribunal found the assessee&#039;s explanation of regrouping entries justified and held PCIT&#039;s direction for further enquiry was unwarranted.</description>
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      <pubDate>Wed, 29 Sep 2021 00:00:00 +0530</pubDate>
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