ACIT (Central) Ujjain v. Italian Edibles Pvt. Ltd (Indore)(Trib)(UR)

S. 115BBE-Tax on specified income-Determination of tax in certain cases-Unaccounted stock declared during survey-Excess stock being part of total business stock-Cannot be assessed as deemed income [S.69, 69B]

Alleged excess stock was not kept separately at any other place and was part of the total business stock found at assessee’s business premises and thus alleged investment in excess stock was part of the business income and, therefore, could not be treated as deemed income under section 69 or 69B liable for taxation under section 115BBE. [AY 2019-20] [ITA No. 219/IND/2022 dated 19/12/2023]