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2022 (9) TMI 961 - ITAT CHANDIGARHEstimation of net profits in absence of reliability of books of accounts - CIT(A) partly allowing the appeal of the assessee by considering net profit to be taken @ 6% instead @ 10% taken by the AO - HELD THAT:- For estimation of profits, either the past history of the assessee which has been accepted and has attained finality or comparable data in case of other assessee involved in the similar line of business would provide a reasonable basis. In the instant case, AO has neither considered the past history or the comparable data of other assessee involved in similar line of business whereas the ld. CIT(A) has considered the past history of the assessee. During the course of hearing, nothing has been brought on record disputing the past history of the assessee which is on record and has been considered by the CIT(A). We therefore do not find any affirmity in the order of the CIT(A) and the same is hereby confirmed. In the result, the ground of appeal taken by the Revenue is dismissed. Addition u/s 68 - whether no supporting evidence had been submitted by the assessee to establish creditworthiness and genuineness of the trade advances? - HELD THAT:- During the course of hearing, our reference was drawn to increase in trade payable during the year and corresponding increase in consumption of raw material during the year and it was submitted that the increase in trade payable is directly linked to purchase and consumption of raw material and where net profit has been estimated, no further disallowance can be made towards the trade payables. We find merit in the contention so advanced by the ld. AR which also find supports from various decisions referred supra and therefore, we do not find any justifiable basis to disturb the findings of the CIT(A) in absence of any contrary material brought on record. In the result, the ground of appeal taken by the Revenue is dismissed.
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