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DCIT, Noida Vs. Pearl Precision Products Pvt. Ltd

Case No: ITA No. 2278/Del/2023
Court: INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH ‘A’
Date: 1/9/2026

Parties Involved

AppellantDCIT, Noida
RespondentPearl Precision Products Pvt. Ltd

Facts Summary

The case pertains to the assessment year 2020-21. Pearl Precision Products Pvt. Ltd, a company involved in manufacturing various household accessories, filed its return of income declaring a total income of ₹21,65,37,670/-. During a survey conducted under section 133A of the Income-tax Act, 1961, on 26/02/2020, a stock difference of ₹1,82,87,179/- was noted between the physical stock and the stock reflected in the stock register. The company explained that the difference was due to sales made on 24th and 25th February 2020, which were not reflected in the excel sheet taken by the survey team. The Assessing Officer (AO) added this difference to the total income of the assessee under section 69A read with section 115BBE of the Act. However, the Commissioner of Income Tax (Appeals)-3, Noida deleted this addition, which led to the present appeal by the revenue.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the ld CIT(A) was justified in deleting the addition of Rs. 1,82,87,179/- on account of alleged stock difference.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

1 precedent cited in this judgement.

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