M/S J.RANJEET JEWELLERS,CHENNAI vs. DCIT, CORPORATE CIRCLE3,, CHENNAI
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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/-.
2 ITA No. 98/Chny/2023
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
3 ITA No. 98/Chny/2023
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.
Order pronounced in the open court on 31st March, 2023
Sd/- Sd/- ( जी. मंजुनाथ ) ( महावीर �संह ) ( G.Manjunatha ) ( Mahavir Singh ) लेखा सद%य / Accountant Member उपा�य�/ Vice-President चे(नई/Chennai, )दनांक/Date: 31.03.2023 DS आदेश क� ��त+ल,प अ-े,षत/Copy to: 1. Appellant 2. Respondent 3. आयकर आयु.त (अपील)/CIT(A) 4. आयकर आयु.त/CIT 5. ,वभागीय ��त�न2ध/DR 6. गाड� फाईल/GF.
