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2023 (2) TMI 1068 - ITAT MUMBAIEstimation of income - Bogus purchases - CIT(A) estimated the profit percentage at 15% - HELD THAT:- It is not in dispute that the assessee had declared gross profit of 10.75% on overall sales (i.e both domestic and export) in its return. It is not in dispute that the sales made out of disputed purchases were not doubted by the revenue in the instant case. Hence it would be just and fair to bring to tax only the profit element embedded in the value of such disputed purchases. Considering the peculiar business model operated by the assessee and considering the fact that the stock registers furnished by the assessee were not disputed by the revenue, we hold that adoption of gross profit percentage of 15% less gross profit declared by the assessee at 10.75% would meet the ends of justice in the peculiar facts and circumstances of the instant case. Accordingly, the ground numbers raised by the assessee and ground raised by the revenue are partly allowed.
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