Awaji Ganapathi Bhat Vittal Vs DCIT (ITAT Bangalore)
In Awaji Ganapathi Bhat Vittal vs DCIT (A.Y. 2018-19), addition of ₹54.69 lakh was made u/s 69 on alleged excess stock found during survey in a jewellery business. The AO relied on survey-based stock working, while the assessee contended that the survey calculation used provisional figures since accounts were not finalized and ignored audited closing stock subsequently accepted by the department.
The ITAT noted that the survey party computed book stock using incomplete data, whereas audited accounts showed higher closing stock as on 31-03-2017, which had already been accepted in earlier assessment. As explained in the working discussed around pages 9–10, correct reconciliation showed actual excess stock difference of only ₹19,46,342, which the assessee had already offered in the return of income.
Holding that the AO’s computation was inflated due to incorrect stock valuation method during survey, the Tribunal deleted the addition of ₹54.69 lakh and directed that only the already disclosed amount of ₹19.46 lakh be retained. The appeal was partly allowed
FULL TEXT OF THE ORDER OF ITAT BANGALORE
Per Prashant Maharishi, Vice President
1. ITA No. 691/Bang/2025 for assessment year 2018 – 19 is filed by Awaji Ganapathi Bhat Vittal (the assessee/appellant) against the appellate order passed by the CIT(Appeals)-11, Bangalore (the learned CIT – A) dated 27th of January 2025 wherein the appeal filed by the assessee against the reassessment order passed by the Deputy Commissioner of Income Tax, Central Circle – 1 (1), Bengaluru (the AO) under section 147 the Income Tax Act, 1961 [the Act] dated 31st of March 2023, was dismissed.
