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    <title>2026 (5) TMI 831 - ITAT DELHI</title>
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    <description>Where income is estimated by gross profit rate and the immediately preceding year is not comparable because turnover and market conditions have materially changed, the average gross profit rate of the preceding five assessment years is the proper benchmark; if that average is below the declared rate, no addition arises. The gross profit estimation issue was decided in favour of the Revenue, subject to recomputation on that basis. The deletion of disallowance of business promotion expenses was set aside for factual verification, as the supporting bills and invoices had not been properly examined by the Assessing Officer; the matter was remanded for fresh decision in accordance with law.</description>
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    <pubDate>Wed, 08 Apr 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=791629</link>
      <description>Where income is estimated by gross profit rate and the immediately preceding year is not comparable because turnover and market conditions have materially changed, the average gross profit rate of the preceding five assessment years is the proper benchmark; if that average is below the declared rate, no addition arises. The gross profit estimation issue was decided in favour of the Revenue, subject to recomputation on that basis. The deletion of disallowance of business promotion expenses was set aside for factual verification, as the supporting bills and invoices had not been properly examined by the Assessing Officer; the matter was remanded for fresh decision in accordance with law.</description>
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