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    <title>2025 (5) TMI 279 - ITAT DELHI</title>
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    <description>ITAT Delhi dismissed both assessee and Revenue appeals in assessment u/s 153C involving unaccounted receipts. CIT(A) had determined 10% of total receipts as taxable unaccounted income based on seized materials showing suppressed turnover. ITAT upheld this estimation, finding rational nexus between seized evidence and income calculation. Court relied on seized documents from group concern showing average 10% net profit margin and noted AO had accepted similar profit rates in related cases. ITAT emphasized additions under s.153C must be based on incriminating materials found during search, citing Delhi HC precedents. The profit estimation was deemed scientifically arrived at from seized materials, making additions sustainable.</description>
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    <pubDate>Tue, 29 Apr 2025 00:00:00 +0530</pubDate>
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      <title>2025 (5) TMI 279 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=770007</link>
      <description>ITAT Delhi dismissed both assessee and Revenue appeals in assessment u/s 153C involving unaccounted receipts. CIT(A) had determined 10% of total receipts as taxable unaccounted income based on seized materials showing suppressed turnover. ITAT upheld this estimation, finding rational nexus between seized evidence and income calculation. Court relied on seized documents from group concern showing average 10% net profit margin and noted AO had accepted similar profit rates in related cases. ITAT emphasized additions under s.153C must be based on incriminating materials found during search, citing Delhi HC precedents. The profit estimation was deemed scientifically arrived at from seized materials, making additions sustainable.</description>
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