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2019 (12) TMI 319 - AT - Income TaxNet Profit on unaccounted receipts - assessment for the block period u/s 158BC - HELD THAT:- We direct the AO to recompute the undisclosed income of the assessee by considering the following:- (i) If the assessee has already filed returns of income for the AYs 1999-2000 to 2002-03, then the receipts which are disclosed in the said returns of income should be reduced from the total receipts considered by the AO to arrive at the undisclosed receipts of the relevant A.Ys. (ii) For the AY 2003-04 also, the actual figures of unaccounted cash receipts should be considered. (iii) The Net Profit on such unaccounted receipts from the AY 1999-2000 to 2003-04 should be estimated at the rate of net profit offered by the assessee on its unaccounted turnover. Since the AO has not brought out any comparable cases and the assessee also is only relying on comparable cases where there are losses, we are constrained to direct as above. In the peculiar facts and circumstances of this case, we direct the AO to estimate the net profit as offered by the assessee in its returns of income even on the unaccounted gross receipts arrived at as directed above.
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