Dismissing the appeal of the revenue , the Court held that ; when undisclosed purchases are discovered in the course of survey ,only profit embedded in transaction can be added as income .Followed Vijay Trading v. ITO ( 2016) 388 ITR 377 ( Guj) (HC).
PCIT v. Subarna Rice Mill (2018) 257 Taxman 509 (Cal.)(HC) Editorial: SLP of revenue is dismissed due to low tax effect ,PCIT v. Subarna Rice Mill ( 2020 ) 269 Taxman 565 (SC)
S. 69C : Unexplained expenditure – Survey- Undisclosed stock -When undisclosed purchases are discovered- Only profit embedded in transaction can be added as income .[ S. 4, 133A, 145 ]