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2018 (6) TMI 1181 - AT - Income TaxGP estimation - rejection of books of accounts - Held that:- Without pointing out any specific defects / deficiencies in the books, it was not justified in rejecting books of accounts merely because the assessee reflected low Gross Profit. Proceeding on the same analogy, estimating the profit merely on the basis of profit reflected by the comparables was not justified and therefore, the action of Ld. AO, to that extent, could not be sustained. The assessee was dealing in varied quality of diamonds, the price of which ranged from $28 to $9400 which necessitate the assessee to maintain adequate quantitative as well as qualitative details of stock so as to arrive at the true profits for the impugned AY. The assessee has apparently not maintained these qualitative details and merely harping on the point that furnishing of quantitative details was sufficient enough to discharge the obligation casted on him in this regard. We are not convinced with the same particularly in view of the fact that the assessee has undertaken majority of the transactions with the related party. Further, we find that the month-wise quantitative details as given in summary of stock for the period 2009-2010 do not matches with ledger extract of monthly summary of cut & polished diamonds. Keeping in view the totality of facts, we deem it fit to restore the matter back to the file of Ld. AO for re-appreciation of the books of accounts of the assessee and profitability reflected therein. Revenue’s appeal stands allowed for statistical purposes
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