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    <title>2026 (3) TMI 606 - ITAT BANGALORE</title>
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    <description>A liquor licence holder&#039;s receipts were confined to a fixed monthly licence consideration under merchandise agreements, while liquor purchased in his name was transferred to merchandisers on a cost-to-cost basis. On the facts, no material showed that he carried on the retail business, controlled day-to-day operations, or earned trading margins. With no specific defects in the accounts and one identical arrangement accepted by the Revenue in the same year, profit could not be estimated at 5% on purchases. The addition based on presumed business income was deleted, reflecting that trading profit cannot be assumed where genuine merchandise arrangements limit the assessee&#039;s income to fixed licence receipts.</description>
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