ITAT Upholds Tax on Excess Stock as Business Income, Dismisses Revision u/s 263 in Survey Case.

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....Revision u/s 263 - Additions u/s 69 r.w.s. 115BBE - excess stock found during the course of survey as admitted to be the undisclosed business income of the assessee, by the main partner in the assessee firm - The ITAT found that since the department did not find other sources of income during the survey, it was reasonable to treat the excess stock as business income. Therefore, the AO's decision was not erroneous, and the invocation of revision powers under Section 263 - The Tribunal observed that the excess stock was not separately identifiable and was part of a mixed lot found during the survey. Considering precedents and the nature of the excess stock, it was deemed to be the business income of the assessee. Therefore, the AO's decision to tax it as business income was upheld.....