Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2020 (1) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2020 (1) TMI 448 - ITAT HYDERABADN.P. Determination - assessee was into the business of selling of vegetables both from the dealers as well as farmers - Bifurcation of business categories - HELD THAT:- Assessee himself had contended before the AO that his trading activities are to be bifurcated into two categories i.e. selling vegetables on behalf of farmers and on behalf of dealers and retailers. CIT(A) seems to have mis-read the Note given by the assessee as he has recorded that the assessee has not stated that he has sold vegetables on behalf of farmers. The assessee in his Note has mentioned ‘farmers’ who are also known as agriculturists. However, I also find that the assessee has failed to bifurcate the sales and also in estimating of profit from such sales. Therefore, no discrepancy in CIT(A)’s adopting the same rate of net profit declared by assessee on the declared turnover to the undisclosed turnover as well. However, in the peculiar circumstances of the case, the net profit can be reduced to do justice to the assessee. Therefore, direct the AO to adopt 6.5% as net profit on the entire turnover of the assessee. However, make it clear that this finding shall be effective only for the relevant A.Y. and cannot be adopted as precedent for any other A.Y. - Assessee’s appeal is partly allowed.
|