M/S J.RANJEET JEWELLERS,CHENNAI vs. DCIT, CORPORATE CIRCLE3, CHENNAI
In favour of the Revenue: the assessee's appeal was dismissed. From the AI summary of this appeal.
What did the Tribunal hold?
The Tribunal found no infirmity in the orders of the lower authorities. It confirmed the addition made by the Assessing Officer on account of profit on the deficit stock.
What were the facts?
During a survey, a stock deficit of silver articles valued at Rs. 29,80,955 was found. The Assessing Officer estimated profit on this deficit, considering it as unaccounted sales, and made an addition. The CIT(A) confirmed this addition.
What were the issues?
Whether the profit estimated on the deficit stock found during a survey, treated as unaccounted sales, is sustainable.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, ‘C’ BENCH, CHENNAI
Before: SHRI MAHAVIR SINGH, VICE- & SHRI G.MANJUNATHA
PER MAHAVIR SINGH, VP: This appeal by the assessee is arising out of order passed by the Commissioner of Income Tax (Appeals)-18, Chennai dated 14.12.2022. The assessment was completed by the DCIT., Central Circle-3(4), Chennai for relevant assessment year 2019-20 u/s. 143(3) of the Income Tax Act, 1961 (hereinafter “the Act”) vide order dated 26.09.2021.
The only issue in this appeal of the assessee is as regards to order of the CIT(A) estimating profit and making addition of Rs.2,92,729/-.
We have heard rival contentions and gone through facts and circumstances of the case. We noted that the assessee is engaged in wholesale business of silver articles and anklets. A survey u/s.133A was carried out in the business premises of the assessee and during the course of survey deficit stock of 81.067 kgs of silver articles and anklets valued at Rs.29,80,955/- was found. The Assessing Officer considering into stock deficit found during the course of survey estimated deficit to unaccounted sales and estimated gross profit rate at 9.82%, as declared by the assessee in his regular business.
Accordingly, addition of Rs.2,92,729/-, being profit on deficit stock of Rs.29,80,955 was added.
The CIT(A) also confirmed action of the Assessing Officer and noted that explanation given by the assessee that there are two challans of sales of silver to two persons viz., J.Ranjeetmal Challani and Akshay Chhallani are an afterthought and perverted invoices to post-survey. Even, the assessee could not provide any details during the course of survey that sale has been effected, hence, he confirmed action of the Assessing Officer in assessing profit rate on unaccounted sale of Rs.2,92,729/-.
We have also gone through facts in entirety and arguments of both sides and we find no infirmity in the orders of lower authorities and hence, we confirm the addition made by the Assessing Officer and appeal of the assessee is dismissed.
In the result, appeal of the assessee is dismissed.
More judgments on Section 133A
- ACIT Central Bilaspur, Bilaspur vs Arun Kumar Agrawal, SaktiITSSA 26/RPR/2025[2018-19]Status: Disposed21 Oct 2026AY 2018-19
- Venish Vinodray Lalani, Rajkot vs Income Tax Officer, MorbiITA 197/RJT/2026[2019-20]Status: Disposed19 Oct 2026AY 2019-20
- Ranchhodbhai Kurjibhai Kakadiya, Rajkot vs Income Tax Officer, Ward-1(1)(1), RajkotITA 553/RJT/2025[2019-20]Status: Disposed16 Oct 2026AY 2019-20
- Amr Infrastructures, Hyderabad vs DCIT., Central Circle-2(1), HyderabadITA 818/HYD/2025[2020-21]Status: Disposed16 Oct 2026AY 2020-21
- Shri Vikaskumar Macwan, Nadiad vs Dc/ACIT Central Circle 3, VadodaraITA 2022/AHD/2026[2020-21]Status: Disposed13 Oct 2026AY 2020-21
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