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2020 (12) TMI 94 - AT - Income TaxRecasting the income of the assessee - NP determination - Whether import purchase amount shown by the Ld. CIT(A) in the recast is erroneous? - HELD THAT:- As purchase amount as evident from books and other records is ₹ 16,20,796/-. We note that the Ld. CIT(A) has accepted this figure of import-purchase after taking note that assessee imported the goods against LC and the entire transaction took place through banking channel as well as there were bills of entry and invoices, so when the Ld. CIT(A) has accepted the purchase of goods on import as ₹ 16,20,796/-, the Ld. CIT(A) erred while recasting to adopt the figure of ₹ 14,60,834/- when the actual purchase price of goods on import was ₹ 16,20,796/-, so there is a difference of ₹ 1,69,962/-[₹ 16,20,796/- - ₹ 14,60,834]. We note that the N.P % shown by the assessee for export of fish dust after recast of export sale account is 21.5% which is reasonable and moreover considering the fact that the action of Ld. CIT(A) will result in N.P of 46%, which will be high and unreasonable. We direct the AO to accept the re-casted export sale account of assessee, wherein the assessee has shown N.P of 21.5% i.e. ₹ 6,70,968/- and accordingly compute the tax. Appeal of assessee is allowed.
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