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2017 (6) TMI 388 - ITAT DELHIN.P. determination - best judgment assessment - Held that:- Before us, the ld. counsel had brought on record that in the earlier year, the net profit rate of 2.46% was applied in scrutiny proceedings in section 143(3) in the A.Y. 2009-10 on a turnover of ₹ 2.01 crore. Apart from that, the ld. counsel has also pointed out that some of discounts available from the distributor is passed on to the customers and therefore, the assessee’s profit margin gets further reduced. Looking to the fact that it is a case of best judgment assessment; other attended circumstances; materials available on record; and also assessee’s past history, we are of the opinion that it would be fair to apply a net profit of 3% of the total sales of ₹ 1,20,76,727/-. Such an estimate of an income would be reasonable taking into consideration the past history wherein the net profit rate has been estimated 2.46%. AO is thus directed to assess the income accordingly.
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