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Income Tax - Highlights / Catch Notes

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The ITAT rejected the assessee's books of accounts as unreliable ...


Tribunal Finds Business Profits at 2.21%, Rejects Unreliable Accounts and Prevents Double Taxation Under Section 143(3)

April 17, 2025

Case Laws     Income Tax     AT

The ITAT rejected the assessee's books of accounts as unreliable and estimated business profits at 2.21% instead of the 0.47% originally returned. The Tribunal upheld the CIT(A)'s decision based on identical circumstances found in a sister concern's case. The Tribunal rejected the Revenue's argument for a higher profit rate and found the proposed comparable entity to be in a different business line. The Tribunal clarified that the estimated income should subsume previous disallowances to prevent double taxation, ensuring the total income computation matches the 2.21% of turnover estimation. Consequently, the Tribunal upheld the CIT(A)'s order, rejecting separate additions for unaccounted sales and unexplained expenditure as these were already incorporated in the profit estimation.

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