9911796707
TMI Blog2021 (10) TMI 828X X X X Extracts X X X X X X X X Extracts X X X X ..... cturer and dealer in watches, filed return of income on 30.09.2009 declaring income of Rs..8,87,250/- for the A.Y.2009-10 and the return was processed u/s. 143(1) of the Act. Subsequently, Assessing Officer received information from the Investigation Wing of the Income Tax Department, Mumbai about the accommodation entries provided by various dealers and assessee was also one of the beneficiary from those dealers. The assessment was reopened U/s. 147 of the Act based on the information received from Investigation Wing of the Income Tax Department, Mumbai, that the assessee has availed accommodation entries from various dealers who are said to be providing accommodation entries without there being transportation of any goods. In the reassess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or the assessee further submitted that the addition made by the Ld.CIT(A) is on higher side, thus requested to reduce the same. Ld. Counsel for the assessee referring to the written submissions stated that the Gross Profit to sales ratio of the assessee is around 9% and this is also the industrial standard in which the assessee operates. Ld. Counsel for the assessee submits that the Gross Profit ratio of the last three preceding assessment years under appeal arrived by taking the figures from the audited financial statements are as under: - Particulars AY 2008-09 AY 2007-08 AY 2006-07 Sales 6,86,58,909/- 6,99,66,438/- 6,14,27,895/- Cost of Sales 6,20,88,452/- 6,33,01,547/- 5,62,05,964/- Gross Profit (G. P.) 65,70, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e that the purchases made are from the parties as claimed, especially in the absence of any confirmations from them. As could be seen from the average Gross Profit ratio to sales of the assessee for the last three preceding Assessment Years i.e. A.Y. 2006-07 to A.Y. 2008-09 it is arrived at 9.19% and the Gross Profit margin of the assessee for the current assessment year i.e. A.Y. 2009-10 is 9.17%. Therefore, taking the totality of facts and circumstances, keeping in view the nature of business of the assessee i.e. trader in manufacturer and dealer in watches, and the Gross Profit ratio to sales for the last three preceding assessment years and also current assessment year it would be justified if the profit element embedded in those purcha ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
