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    <title>2025 (12) TMI 1215 - ITAT DELHI</title>
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    <description>The dominant issue was the quantum of addition under s. 68/GP estimation where the assessee&#039;s sales were treated as accommodation entries based on survey statements admitting control of entities used to provide such entries. The AO added amounts by treating sales as bogus while ignoring that corresponding purchases were also accommodation entries, and that the assessee had already recorded a declared GP of 17.08% on such transactions; thus only an element of profit could be brought to tax. The appellate authority rightly confined the addition to &quot;bogus profit,&quot; but since the declared GP already stood credited in the books, the Tribunal held that a penal estimation was warranted and restricted the disallowance to 5% of gross sales.</description>
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      <title>2025 (12) TMI 1215 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=783675</link>
      <description>The dominant issue was the quantum of addition under s. 68/GP estimation where the assessee&#039;s sales were treated as accommodation entries based on survey statements admitting control of entities used to provide such entries. The AO added amounts by treating sales as bogus while ignoring that corresponding purchases were also accommodation entries, and that the assessee had already recorded a declared GP of 17.08% on such transactions; thus only an element of profit could be brought to tax. The appellate authority rightly confined the addition to &quot;bogus profit,&quot; but since the declared GP already stood credited in the books, the Tribunal held that a penal estimation was warranted and restricted the disallowance to 5% of gross sales.</description>
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      <pubDate>Wed, 10 Dec 2025 00:00:00 +0530</pubDate>
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