ITAT allowed the assessee's appeal and deleted the addition u/s...

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.