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The case involves bogus purchases u/s 69C, with the assessee dealing in bullion. The Gross Profit (GP) rate estimation is crucial. The assessee argued that the GP rate for bullion cannot exceed 0.15%, supported by a demonstrated 0.13% GP rate on sales. It was shown that if purchases are deemed bogus, the GP percentage would unreasonably inflate to 26%. The addition of entire purchases was deemed unsustainable. Even if purchases were from other vendors, the maximum profit margin was held at 0.15%. The Appellate Tribunal directed the Assessing Officer to use a 0.15% GP rate for disputed purchases instead of the 0.13% claimed by the assessee, partly allowing the appeal.
The case involves bogus purchases u/s 69C, with the assessee dealing in bullion. The Gross Profit (GP) rate estimation is crucial. The assessee argued that the GP rate for bullion cannot exceed 0.15%, supported by a demonstrated 0.13% GP rate on sales. It was shown that if purchases are deemed bogus, the GP percentage would unreasonably inflate to 26%. The addition of entire purchases was deemed unsustainable. Even if purchases were from other vendors, the maximum profit margin was held at 0.15%. The Appellate Tribunal directed the Assessing Officer to use a 0.15% GP rate for disputed purchases instead of the 0.13% claimed by the assessee, partly allowing the appeal.
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