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2023 (7) TMI 1204 - ITAT CHANDIGARHGP estimation - quantum of contract receipts taxable in the hands of the assessee company - application of net profit rate - CIT(A) to uphold the action of the AO in applying 13% net profit rate on part of the contract receipts in the hands of assessee - contract receipts which were not part of the books of accounts but very much offered to tax as part of the revised return of income - HELD THAT:- There is no dispute that the assessee can be allowed the benefit of indirect expenses only once while working out its taxable income. However, when the same principle is applied to the facts of the present case, we find that the net profit rate of 3.45% has been determined as a percentage of the total contract receipts which includes both types of contract receipts which are reflected in the books of account which are not reflected in the books of accounts. Where the net profit rate is determined as a percentage of the contract receipts it will shown net profit rate of 0.69% after allowing indirect expenses and net profit rate of 13% as a percentage of contract receipt without allowing any double deduction for indirect expenses. We therefore find that there is no double deduction of indirect expenses while determining net profit rate of 3.45% and given that the assessee has already offered net profit rate of 10% on total contract receipts, no further addition is required to be made in the hands of the assessee. Thus, the addition so sustained by the ld CIT(A) is hereby directed to be deleted. Assessee appeal allowed.
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