2023 (1) TMI 326 - HC - Income Tax
Rejection of books u/s 145 - NP estimation - AO held estimating the net profit at 0.05 % of the assessee company - HELD THAT: - There has been equitable balance struck by the authorities when it found that the Assessing Officer had not given any internal or external comparitive figures of sector of the assessee’s business while arriving at the GP/NP ratio of 7%. The business is of trading of steel items. The manufacturing activities had almost stopped.
NP ratio of 7% being impractical and completely unacceptable and as most of the trading concerns have been operating at the GP ratio of 0.5% to 1%, when both the authorities have deemed it appropriate to apply 0.5% ratio, no indulgence is necessary. These are all essentially and predominantly the factual aspects analysed based on the material adduced before these authorities and that also by giving cogent and sound reasons, in absence of any question of law, much less any substantial questions of law for the court to admit this matter, this appeal is dismissed.