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2018 (10) TMI 189 - AT - Income TaxEstimation of income - Undisclosed bank transactions - trading transactions of its regular course of business - Held that:- It is an admitted fact that the assessee had not disclosed the transaction reflected in the two bank accounts, the details of which are given in the earlier paragraph and the total transactions of which comes to ₹ 29.26 crores. AO rejected the offer of 0.30% given by the assessee during the course of assessment proceedings and estimated the income from such undisclosed transaction on account of cheque discounting at 3% of the total transactions. The assessee has filed certain decisions to substantiate that the profit element in such type of business varies from 0.15% to 0.25%, however, the fact remains that the assessee himself has offered profit of 0.30% before the AO which was rejected by him who estimated such income at 3%. Therefore, the question is that what percentage should be adopted for such transactions which remain undisclosed to the department in the instant case. The offer by the assessee appears to be too low and profit estimated by the Assessing Officer also appears to be on the higher side if we consider such rate of profit in the light of the various decisions cited before us. Adoption of 0.5% as net profit on such undisclosed transactions outside the books, in our opinion, will meet the ends of justice. The grounds raised by the assessee are accordingly partly allowed.
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