Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
ITAT allowed the appeal of the assessee and set aside the assessing officer's rejection of books and deemed income estimate of 2% of sales, holding that the assessee operated as a pass-through processor with negligible control and thin purchase-commission margins. The Tribunal found the assessee regularly declared gross profit of c.0.29% and noted the AO ought to have examined the buyer group by issuing notice under s.133(6). Having regard to comparable precedents and the assessee's scale vis-Ã -vis large group operations, the ITAT fixed estimated profit at 0.40% of gross sales and directed consequential relief, thereby allowing the appeal.
ITAT allowed the appeal of the assessee and set aside the assessing officer's rejection of books and deemed income estimate of 2% of sales, holding that the assessee operated as a pass-through processor with negligible control and thin purchase-commission margins. The Tribunal found the assessee regularly declared gross profit of c.0.29% and noted the AO ought to have examined the buyer group by issuing notice under s.133(6). Having regard to comparable precedents and the assessee's scale vis-Ã -vis large group operations, the ITAT fixed estimated profit at 0.40% of gross sales and directed consequential relief, thereby allowing the appeal.
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