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2023 (7) TMI 737 - ITAT DELHIReopening of assessment u/s 147 - assessee has not filed his return of income and gross receipts of the assessee were very high - HELD THAT:- Because the assessee has not filed his return of income and because the gross receipts of the assessee were very high, the AO assumed jurisdiction u/s 148 of the Act and initiated reassessment proceedings. There is no error or infirmity in this action of the AO. This ground taken is dismissed. GP estimation - When the bench pointed out that let the AO verify and examine the reconciliation, the assessee reluctantly once again showed his inability and insisted the bench to decide the quarrel here itself. Considering the history of the assessee, we are left with no choice but to accept the gross receipts shown in Form No. 26AS as true and correct as on such receipts, payers have deducted tax at source and the assessee has claimed the same as prepaid taxes. Applying the profit rate of 8%, profit to be calculated. AO is directed to frame assessment at these incomes and allow the claim of deduction under Chapter VIA, details of which shall be provided by the assessee. AO is also directed to give credit of TDS as per Form 26AS.
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