https://www.taxtmi.com/caselaws?id=783435 ITAT Mumbai allowed the assessee's appeal, deleting the addition made u/s 28 based on the AO's and CIT(A)'s application of an average GP rate on item-wise Cascade tag prices. The Tribunal held that a GP rate of 15.65% on cost, determined on an aggregated basis from comparable cases and broadly matching the assessee's own 16.86% GP on cost, could not be mechanically applied item-wise, as it is unrealistic to expect identical GP on each item. It accepted that Cascade tag prices were only reference/marketing prices, final sale prices were correctly recorded in Tally, and no incriminating material or undisclosed assets supported the allegation of suppressed sales. en-us Thu, 11 Dec 2025 00:00:00 +0530 Mon, 15 Dec 2025 14:33:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783435 ITAT Mumbai allowed the assessee's appeal, deleting the addition made u/s 28 based on the AO's and CIT(A)'s application of an average GP rate on item-wise Cascade tag prices. The Tribunal held that a GP rate of 15.65% on cost, determined on an aggregated basis from comparable cases and broadly matching the assessee's own 16.86% GP on cost, could not be mechanically applied item-wise, as it is unrealistic to expect identical GP on each item. It accepted that Cascade tag prices were only reference/marketing prices, final sale prices were correctly recorded in Tally, and no incriminating material or undisclosed assets supported the allegation of suppressed sales. Case-Laws Income Tax Thu, 11 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783435