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    <title>2025 (6) TMI 1769 - ITAT KOLKATA</title>
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    <description>The ITAT dismissed the Revenue&#039;s appeal regarding addition of Rs. 69,10,285/- under section 69 as unexplained investment. During survey, a partner admitted unaccounted sales but these were subsequently recorded in books and included in audited accounts. The AO erred by treating the entire amount as unexplained investment without applying gross profit ratio. The CIT(A) correctly applied 6% GP ratio to estimate taxable income at Rs. 4,14,617/- and deleted the balance Rs. 64,95,668/- from addition. The ITAT upheld this approach, citing Gujarat HC precedent in Rameswar Textile Mills Ltd that unaccounted sales require GP ratio application rather than full addition as unexplained investment.</description>
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    <pubDate>Mon, 23 Jun 2025 00:00:00 +0530</pubDate>
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      <title>2025 (6) TMI 1769 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=773656</link>
      <description>The ITAT dismissed the Revenue&#039;s appeal regarding addition of Rs. 69,10,285/- under section 69 as unexplained investment. During survey, a partner admitted unaccounted sales but these were subsequently recorded in books and included in audited accounts. The AO erred by treating the entire amount as unexplained investment without applying gross profit ratio. The CIT(A) correctly applied 6% GP ratio to estimate taxable income at Rs. 4,14,617/- and deleted the balance Rs. 64,95,668/- from addition. The ITAT upheld this approach, citing Gujarat HC precedent in Rameswar Textile Mills Ltd that unaccounted sales require GP ratio application rather than full addition as unexplained investment.</description>
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      <pubDate>Mon, 23 Jun 2025 00:00:00 +0530</pubDate>
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