ACIT v. Akash Gurudas Talreja (2023)102 ITR 52 (SN)(Pune) (Trib)

S. 143(3): Assessment-Survey-Gross profit rate-Unaccounted sales-No material to indicate the assessee indulged in unaccounted sales post survey-Addition reduced considering electricity consumption-Justified. [S.133A]

Held that the entire edifice of the addition has been made by the Assessing Officer only in the realm of extrapolation of the figures of unaccounted turnover before the date of survey to the period post survey. There was no material to indicate, even remotely, that the assessee indulged in unaccounted sales during the post survey period as well. The Commissioner (Appeals) reduced the amount of addition  considering the electricity consumption. The part deletion by the Commissioner (Appeals) is   justified.(AY.2016-17)