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2018 (2) TMI 1775 - AT - Income TaxEstimation of net income - N.P. determination - Held that:- A.O. as well as Ld. CIT(A) have relied upon the decisions of the ITAT rendered in 2011 / 2012 whereas the Assessing Officer, under similar circumstances, made scrutiny assessments wherein the stringent change in policy as well as impact of the High Court directions were taken into consideration for the purpose of estimating the net income @ 3% and in fact in the later decisions of the Tribunal, the net income was estimated @ 3% of the cost of goods sold. Under these circumstances we direct the A.O. to adopt 3% of the cost of the goods sold as the income of the assessee.
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