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Undisclosed income - gross profit margin on unaccounted sales - It is quite possible that the assessee was able to generate more profit post search period depending upon the quality of blocks. Hence it may not be correct on the part of the AO to consider the post search period results for determining the gross profit margin of unaccounted sales despite the fact that the gross profit margin worked out by the assessee has been accepted by the search officials, i.e., another wing of the income tax department. Hence, what the AO has done is to substitute one estimation with another one, which is not warranted in the facts of the present case. - AT
Undisclosed income - gross profit margin on unaccounted sales - It is quite possible that the assessee was able to generate more profit post search period depending upon the quality of blocks. Hence it may not be correct on the part of the AO to consider the post search period results for determining the gross profit margin of unaccounted sales despite the fact that the gross profit margin worked out by the assessee has been accepted by the search officials, i.e., another wing of the income tax department. Hence, what the AO has done is to substitute one estimation with another one, which is not warranted in the facts of the present case. - AT
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