Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
ITAT allowed the assessee's appeal and deleted the addition u/s 28 arising from the AO's application of average gross profit (GP) on item-wise Cascade tag prices and the 50% adjustment to such tag prices. The Tribunal held that a GP rate of 15.65% on cost, derived on an aggregate basis from comparable cases, was reasonable and already aligned with the assessee's overall GP of 16.86%. It ruled that applying this aggregate GP to compute item-wise margins was irrational, given varied profitability and even loss-making items. ITAT accepted that Cascade tag prices were only indicative, with actual sale prices correctly recorded in regular books, and found no incriminating material to justify additions.
ITAT allowed the assessee's appeal and deleted the addition u/s 28 arising from the AO's application of average gross profit (GP) on item-wise Cascade tag prices and the 50% adjustment to such tag prices. The Tribunal held that a GP rate of 15.65% on cost, derived on an aggregate basis from comparable cases, was reasonable and already aligned with the assessee's overall GP of 16.86%. It ruled that applying this aggregate GP to compute item-wise margins was irrational, given varied profitability and even loss-making items. ITAT accepted that Cascade tag prices were only indicative, with actual sale prices correctly recorded in regular books, and found no incriminating material to justify additions.
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