Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
