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2019 (2) TMI 1946 - AT - Income TaxUnaccounted sales - Addition based on loose sheets found in search - difference in purchase of milk as per daily milk procurement sheets and as recorded in the books - HELD THAT:- The entire unaccounted sales cannot be added because there has to be some purchases and expenses related therewith. Therefore, making addition on the basis of profit margin is more logical and rationale. Moreover, though the daily milk procurement sheets were found but no document was found wherein the revenue can say that the assessee was also making undisclosed purchases. The most important fact which needs to be highlighted is that the Assessing Officer, in his whims and surmises, has considered the extrapolation for only two A. Ys whereas, if he was so confident about the seized documents and income therein, he should have extrapolated for the entire block period of six years. AO did not give any reason for this. Considering the facts of the case in totality, we are of the considered opinion that the CIT(A) rightly deleted the additions made by the Assessing Officer but erred in sustaining the addition which, In our considered opinion, on facts discussed hereinabove, needs to be deleted also.
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