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2013 (10) TMI 209 - AT - Income TaxAssessment u/s 153A pursuant to search - estimation of rate of net profit - Whether the rate of profit shown in return is reasonable or not - Selection of Comparables for the computation of rate of profit – Held that:- Comparison with other cases must taken into account the total turnover, the favourable or unfavourable conditions of the assessee vis-à-vis comparable cases, etc - There are two related parties carrying an identical business of running of bakery viz. Sri Abdul Gadhafi and Smt. Thasleena P.P. in whose cases my predecessor has held that net profit rate of 11% and 5% respectively - The net profit rates shown by the appellant in the revised returns are considered as unfair and unreasonable - The reasonable and justifiable net profit rate that is required to be adopted in the appellant’s case is determined at 8.00% for the reason that the peak net profit rate worked out on the basis of appellant’s revised income for assessment year 2006-07 and 07-08 are above 7% - Net profit rate @ 8% should be adopted on the estimated turnover as upheld in this proceedings for the impugned assessment years – Decided against the Assessee.
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