DCIT Vs Yagneshkumar Gandhi (ITAT Ahmedabad)
ITAT Ahmedabad held that addition of entire amount as unaccounted sales not justified since undisclosed income is required to be computed on the basis of principle of real income. Accordingly, addition of only net profit of such receipt confirmed.
Facts- The assessee is an individual and Proprietor of M/s. Astamangal engaged in the business of manufacturing of gold chain jewellery, retail and wholesale trading of gold jewellery. There was a Survey action u/s. 133A of the Act was carried out in the case of the assessee along with other jewellery group of Ahmedabad on 07-02-2020. During the course of assessment proceedings, on perusal of impounded documents, the AO had noticed that there were various entries recorded in Courier, Angadia slips, JPG image sheet, etc found from the assessee’s business premises. On perusal of the materials, the AO found that the said entries recorded in the impounded documents was representing the unaccounted sale to the various parties on various dates by the assessee during the year under consideration. After detailed verification the total amount of unaccounted sales came to Rs.2,67,91,319/-. AO treated the same as unaccounted sales and added to the total income of the assessee, while passing the assessment order and demanded tax thereon.
