9911796707
TMI Blog2025 (1) TMI 654X X X X Extracts X X X X X X X X Extracts X X X X ..... .e Diesel Petrol business range between 2% to 3% and both the revenue authorities has over looked the factual aspects of the purchase transactions substantiated with material evidences filed in compliance to the notices. AR highlighted the clauses of Tax Audit report in Form. no 3CD in particular clause 35(a) and 40. We considering the facts, circumstances, gross profit margin, and omission of ent ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee is a partnership firm and is engaged in the business as dealer in petroleum products. The assessee has filed the return of income on 28-11-2014 disclosing a total income of Rs. 3,00,950/-. Subsequently the case was selected for limited scrutiny under CASS and the notice u/sec143(2) and u/sec 142(1) of the Act along with questionnaire are issued. In compliance, the Ld.AR of the assessee a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al income of Rs. 11,90,778/- and passed the order u/sec 143(3) of the Act dated 6.12.2016. 3. Aggrieved by the order, the assessee has filed an appeal before the CIT(A), whereas the CIT(A) has considered the grounds of appeal, statement of facts and findings of the AO and granted partial relief and sustained balance of Rs. 8,64,744/- and partly allowed the assessee appeal. Aggrieved by the order o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d for allowing the appeal. Per Contra, the Ld. DR supported the order of the CIT(A). 5. We heard the rival submissions and perused the material on record. The Ld.AR submitted that the CIT(A) has erred in sustaining the disallowance overlooking the submissions and the Assessing Officer has not doubted the genuineness of claim of expenditure/ purchases but has made addition in the absence of entries ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of Tax Audit report in Form. no 3CD in particular clause 35(a) and 40. We considering the facts, circumstances, gross profit margin, and omission of entries by the assessee and to meet the ends of justice, restrict the addition @ 5% of the purchase transactions. Accordingly, we set-aside the order of the CIT(A) and direct the assessing officer to estimate the income@5% of disputed purchase value. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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