Excess Trading Stock Found During Survey Cannot Be Taxed Under Section 69B As Unexplained Investment

ITAT determined that excess stock discovered during survey, though surrendered by assessee, cannot be taxed under Section 69B read with Section 115BBE. The undeclared stock, being indistinguishable from regular business inventory and lacking independent physical identity, represents undisclosed business receipts rather than investment. The tribunal reasoned that since the excess stock was part of assessee's regular trading inventory without distinct physical characteristics, it constitutes business income subject to normal tax rates, not unexplained investment under deemed provisions. The difference was purely in value terms, forming part of overall business operations. Accordingly, ITAT allowed assessee's appeal, ruling that normal tax rates apply instead of punitive provisions under Section 115BBE. .....

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