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2021 (12) TMI 408 - HC - Income TaxGP estimation on purchase of liquor - best judgment assessment - HELD THAT:- For the two assessment years, different percentage of gross profits have been taken, the addition for the two years is on the higher side. The assumption of the assessing officer that three star hotels earn huge profits cannot be a proposition of general application. Various factors will determine the extent of profits. Since the assessee failed to maintain the books of account, best judgment assessment was validly resorted to. Though the assessing officer is entitled to enter into some guess work while carrying out the best judgment assessment, we are of the opinion that 70% or even 65% was excessive for the said two years. We are of the considered view that 55% of the gross profit would be a justifiable addition in these two revision petitions. We allow these two revision petitions and direct the sales turn over of liquor to be estimated for the assessment years 2010-11 and 2011-12 by adding gross profit at 55% of the purchase value of liquor and beer sold by the assessee.
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