Addition only for net profit element embedded in alleged undisclosed sale if purchase not doubted

ITO Vs Manumati Boro (ITAT Guwahati) Revenue has challenged the finding of the ld. CIT(A) deleting the addition for undisclosed sale and sustaining the addition only to the extent of net profit element embedded in the alleged undisclosed sale. We notice that the ld. Assessing Officer based on the seized records impounded during the course of survey, made the addition for undisclosed sale of Rs.2,39,42,814/-. The ld. CIT(A) after making a detailed discussion and also referring to various judgments including that of Hon’ble Gujarat High Court in the case of CIT vs. President Industries (2002) ...