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TMI Blog2024 (1) TMI 362X X X X Extracts X X X X X X X X Extracts X X X X ..... Even the Tribunal perused the document shown on the time of hearing on 11.04.2022 and observed that the assessee could not give any bifurcation as to how much was the quantity sold on the particular period related to the gold ornaments and silver ornaments which shows that the assessee deliberately not bifurcated the unaccounted stock and the regular stock during the period from the date of survey till 31st March, 2015 and accordingly, the Tribunal upheld the finding arrived at by the CIT (Appeals). No infirmity in the concurrent findings of fact arrived at by the CIT (Appeals) as well as the Tribunal while upholding the order passed by the Assessing Officer for making addition on account of the admission made by the assessee at the tim ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... me Tax Appellate Tribunal was justified in dismissing the appeal of the assessee without considering the fact that the issue involved? (iv) Whether in the facts of the case as well as law, the Ld. Income Tax Appellate Tribunal was justified in dismissing the Miscellaneous Application for review filed by the appellant against the order dated 06.05.2022? 4.1. The brief facts of the case are that the appellant-assessee who is in business of trading of gold and silver ornaments was surveyed under Section 133A of the Act on 12.12.2017. The case of the assessee was therefore taken up in the scrutiny pursuant to the survey. During the course of survey, excess stock of gold ornaments were found weighing 2773.478 grams and silver ornamen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... here is no counter argument by the appellant. The contention of the appellant is not acceptable as the valuation made on the date of survey will have to be considered as investment in excess stock found on the date of survey. The valuation so made reflects the investments made by the appellant as on date of survey. In answer to question no. 11, the partner during the course of survey had promised to furnish the trial balance and provisional balance sheet as on the date of survey within two days. However, no such details or documents have been furnished till the time of completion of assessment proceedings neither have they been filed in the present proceedings. Had the intention of the appellant been fair, it would have submitted evidences ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ribunal perused the document shown on the time of hearing on 11.04.2022 and observed that the assessee could not give any bifurcation as to how much was the quantity sold on the particular period related to the gold ornaments and silver ornaments which shows that the assessee deliberately not bifurcated the unaccounted stock and the regular stock during the period from the date of survey till 31st March, 2015 and accordingly, the Tribunal upheld the finding arrived at by the CIT (Appeals). 5. We do not find any infirmity in the concurrent findings of fact arrived at by the CIT (Appeals) as well as the Tribunal while upholding the order passed by the Assessing Officer for making addition of Rs. 13,57,865/- on account of the admission made ..... X X X X Extracts X X X X X X X X Extracts X X X X
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