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ITAT ruled on unexplained purchases under s.69C and unaccounted sales. For unexplained purchases in non-edible oil business, ITAT directed estimation of profit at 8% based on industry GP rates and assessee's past performance (weighted average GP of 7.96% during AY 2014-18). Regarding unaccounted sales addition based on seized Shubh Laxmi Group documents, ITAT rejected AO's addition since statement of witness was used without providing cross-examination opportunity, violating natural justice principles. Further, AO had already made additions for unaccounted purchases and short stock as unaccounted sales, making separate sales addition unjustified. ITAT emphasized past trading history as key determinant and applied doctrine of equity in profit estimation.
ITAT ruled on unexplained purchases under s.69C and unaccounted sales. For unexplained purchases in non-edible oil business, ITAT directed estimation of profit at 8% based on industry GP rates and assessee's past performance (weighted average GP of 7.96% during AY 2014-18). Regarding unaccounted sales addition based on seized Shubh Laxmi Group documents, ITAT rejected AO's addition since statement of witness was used without providing cross-examination opportunity, violating natural justice principles. Further, AO had already made additions for unaccounted purchases and short stock as unaccounted sales, making separate sales addition unjustified. ITAT emphasized past trading history as key determinant and applied doctrine of equity in profit estimation.
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