Held, that since there was only shortage of physical stock to the extent of 48.94 carats, only the profit element embedded in the sale transaction could be brought to tax. Therefore, the Assessing Officer was to compute the gross profit portion on the sales and tax the assessee accordingly. Relied on UNI Design Jewellery Pvt. Ltd. v. DY. CIT (I. T. A. No. 2578/Mum/2018, dated December 30, 2019.. (AY. 2009-10 to 2012-13)