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    <title>Appeal Succeeds: Section 28 Addition on Cascade Tag Pricing Deleted, Actual Sales and Aggregate GP Accepted</title>
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    <description>ITAT allowed the assessee&#039;s appeal and deleted the addition u/s 28 arising from the AO&#039;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&#039;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.</description>
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    <pubDate>Tue, 16 Dec 2025 08:19:37 +0530</pubDate>
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      <title>Appeal Succeeds: Section 28 Addition on Cascade Tag Pricing Deleted, Actual Sales and Aggregate GP Accepted</title>
      <link>https://www.taxtmi.com/highlights?id=95087</link>
      <description>ITAT allowed the assessee&#039;s appeal and deleted the addition u/s 28 arising from the AO&#039;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&#039;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.</description>
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      <pubDate>Tue, 16 Dec 2025 08:19:37 +0530</pubDate>
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