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2020 (9) TMI 619 - AT - Income TaxEstimation of income - bogus purchases - HELD THAT:- For the purposes of making the best judgment assessment, past history of the assessee has been held as reliable and reasonable basis for estimation of profits. In the instant case, though the assessee was incorporated on 15.12.2011, no business was carried out in the said year and the current financial year 2011-12 is the effective first year of operations and the question of applying assessee’s past history therefore doesn’t arise for consideration as not relevant. Alternatively, comparable cases in the similar line of business should be considered by the authorities. There is nothing on record in respect of any comparable third party data and therefore, we deem it appropriate to set-aside the matter to the file of the AO for the limited purposes of identifying the comparable third party data and the comparison thereof with gross profit of 8.5% so declared by the assessee and then decide, the quantum of addition basis such variation, if any. The assessee is also directed to identify such comparable data and bring it to the notice of the Assessing officer for his examination and verification.
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