https://www.taxtmi.com/caselaws?id=313903 The ITAT Jaipur rejected the AO's enhancement of sales by Rs. 7.58 crores based on alleged suppression, finding the sample size of 113 cases out of 1459 customers grossly insufficient to justify the inference. The tribunal held that minor variations between delivery memos and customer replies under section 133(6) did not establish suppression, particularly given the small 12.15% difference. The application of 3.25% GP rate was also rejected as it relied on subsequent year data and uncomparable cases. Instead, the tribunal accepted the assessee's revised GP rate of 4.20% and made only an ad hoc addition of Rs. 2 lakhs. Customer advances totaling a small amount were deleted as they represented genuine trade advances with complete customer details provided. en-us Wed, 09 Nov 2022 00:00:00 +0530 Wed, 08 May 2024 17:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313903 The ITAT Jaipur rejected the AO's enhancement of sales by Rs. 7.58 crores based on alleged suppression, finding the sample size of 113 cases out of 1459 customers grossly insufficient to justify the inference. The tribunal held that minor variations between delivery memos and customer replies under section 133(6) did not establish suppression, particularly given the small 12.15% difference. The application of 3.25% GP rate was also rejected as it relied on subsequent year data and uncomparable cases. Instead, the tribunal accepted the assessee's revised GP rate of 4.20% and made only an ad hoc addition of Rs. 2 lakhs. Customer advances totaling a small amount were deleted as they represented genuine trade advances with complete customer details provided. Case-Laws Income Tax Wed, 09 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313903