Assessee-company was engaged in business of selling sarees. During survey conducted at business premises of assessee, Assessing Officer relied on statement of director of assessee-company and made additions on account of undervaluation of stock. Commissioner (Appeals) held that disclosure made in course of survey should not be relied upon and assessment should be based on papers found and impounded during course of survey Addition was deleted. Order of CIT(A) is affirmed by Tribunal. On appeal by the Revenue dismissing the appeal the Court held that Tribunal was right in deleting addition made by Assessing Officer on account of undervaluation of stock by solely relying upon statement of director of assessee-company which was recorded during course of survey proceedings. (AY. 2011-12)
PCIT v. Ambika Sarees (P) Ltd. (2022) 288 Taxman 174 (Cal.) (HC)
S. 145 : Method of accounting-Unexplained investments Undervaluation of stock-Statement of director in the course of survey-Solely relying on statement of director addition cannot be made. [S. 69, 133A]