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TMI Blog2016 (9) TMI 1589X X X X Extracts X X X X X X X X Extracts X X X X ..... ) TMI 1028 - GUJARAT HIGH COURT ]on an analysis of the material, Tribunal drew an inference that in the trade of steel profit at the rate of 12.5% may be reasonable profit when the assessee has procured material from different sources and bills from different sources. This formation of opinion was not disturbed by the Hon ble High Court. Therefore, we find force in the contentions of the ld.co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... resentatives, we have gone through the record carefully. The admitted facts are that the assessee was engaged in trading of steel. According to the AO, purchases having value of ₹ 18,02,736/- could not be proved by the assessee. Therefore, he treated such purchases as bogus. He made addition of ₹ 18,02,736/- to the income of the assessee. Dissatisfied with this addition, the assessee c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2.5% of the purchases. On the other hand, the ld.DR contended that assessee might have been involved in this modus operandi from long back. In this year, he has been caught, and therefore, his total purchases should be added, no deduction ought to be allowed to the assessee on account of purchase cost. 4. On due consideration of the above facts, we are of the view that no doubt the assessee cou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n ble Gujarat High Court. In our opinion, in different trade items, there may be different rate of profit. Whenever any profit is being estimated, the element of guesswork would always be involved. In the case of Simit P. Sheth(supra) on an analysis of the material, Tribunal drew an inference that in the trade of steel profit at the rate of 12.5% may be reasonable profit when the assessee has proc ..... X X X X Extracts X X X X X X X X Extracts X X X X
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