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TMI Blog2017 (7) TMI 1103X X X X Extracts X X X X X X X X Extracts X X X X ..... etals, ferroalloys, etc. Reasonableness of the estimation by the CIT(A) is concerned, it is seen though she has recognized the presumptive rates recommended by the Task Force set up by the Central Government for business of manufacturing and/or trading of diamonds, but has not been fully guided by it. Considering the recommendations and the fact that there is a mix of trading as well as manufa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... appeal, but the solitary dispute is with regard to the level of addition sustained by the CIT(A) by estimating the profit @3% of bogus purchases. 3. Briefly put, the relevant facts are that assessee is a partnership firm, which is engaged in the business of manufacture, export and dealings in precious, semi-precious and gem stones. In the assessment proceedings, the Assessing Officer noted tha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... excessive, inasmuch as, the Task Force Group for diamond industry constituted by the Government of India, Ministry of Commerce and Industry, after considering the BAP scheme had recommenced presumptive tax for net profit calculated @2% for trading activity and 3% for manufacturing activity or @ 2.5% across the board. The Ld. Representative for the assessee pointed out that even if, one has to go b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... been noted by the CIT(A), the products are quite different. The case before me relates to the purchases of precious, semi-precious diamonds and gem stones and in this context the Assessing Officer as well as CIT(A) have not estimated the profit at the level which is normally done in similar cases involving products like metals, ferroalloys, etc. In so far as the reasonableness of the estimation b ..... X X X X Extracts X X X X X X X X Extracts X X X X
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