TMI Blog2011 (12) TMI 637X X X X Extracts X X X X X X X X Extracts X X X X ..... for short] is to the order of the Income Tax Appellate Tribunal, Ahmedabad [ Tribunal for short] dated 22nd March 2010, proposing following substantial question of law :- Whether the Appellate Tribunal is right in law and on facts in reducing the addition made on account of unaccounted sales of man made fabrics from ₹ 4,58,65,874/= to ₹ 75,80,523/= ? Briefly stated, the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n 145 of the Act, treating the entire unaccounted sales as undisclosed income of the assessee. This was challenged before the CIT [A] which reduced the additions from ₹ 4,58,56,874/= to ₹ 3,86,14,825/= thereby giving respite to the assessee to the tune of ₹ 72,00,000/= [ rounded off ]. Revenue had challenged this order of CIT [A] before the Tribunal and had noted that t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . On the ground that the entire undisclosed sales could not be treated as profit of the assessee, relying on the judgment of this Court in the case of CIT v. President Industries Limited , [258 ITR 654 (Guj)], it upheld the findings of the CIT [A] which applies the gross profit ratio against the unaccounted sales for the purpose of making additions on account of undisclosed income. The Tribunal a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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