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2018 (7) TMI 872 - AT - Income TaxAddition made towards unexplained sources for peak credits in ICICI Bank Account but not disclosed in the books of accounts - Held that:- As observed from the order of the Ld. CIT(A), there is credit for closure of deposits made in the account on 5.3.2007 which was also included for arriving the peak balance. It is not explained whether the sources of deposits were disclosed or not in the regular books of accounts. Therefore, while confirming the action of the Assessing officer for making the addition of peak credit balance, we direct the A.O. to work out the peak credit balance correctly, taking into the account of the cash deposits, cash withdrawals and the unexplained undisclosed entries in the bank account - remit the issue back to the file of the A.O. to rework the peak credit balance correctly. Appeal of the revenue on this ground is allowed for statistical purposes. Gross profit addition on unaccounted purchases - CIT(A) restricted the addition to 15% of gross profit - Held that:- A.O. has not brought on record any comparable cases of others or the assessee’s own case in the earlier years for resorting for estimation of income @ 40.25%. Whereas, the CIT(A) has considered the comparable cases and observed that the rate of gross profit from copra was ranging from 4.68% to 13.25% in regular cases where the purchases and sales were accounted and accordingly, sustained gross profit estimation @ 15% of unaccounted purchases. No other evidence was brought on record by the D.R. and the A.R. to controvert the finding given by the Ld. CIT(A) to establish that the income from unaccounted purchases is less than 15%. No reason to interfere with the order of the Ld. CIT(A) and dismiss the appeal of the revenue as well as the cross objection of the assessee on this issue.
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