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    <title>2024 (7) TMI 1791 - ITAT ALLAHABAD</title>
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    <description>After rejection of books of account under section 145(3), gross profit should not be estimated solely by applying the succeeding year&#039;s gross profit rate. Estimation must be made on a fair and reasonable basis, considering the assessee&#039;s overall trading history, including accepted past results as well as the immediately succeeding year. Where the past trading results have been accepted by the department, ignoring them and relying only on the subsequent year&#039;s rate is not a proper basis for addition. The appropriate method in the stated facts was to adopt an average of the gross profit rates from the relevant past and succeeding years.</description>
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      <link>https://www.taxtmi.com/caselaws?id=469677</link>
      <description>After rejection of books of account under section 145(3), gross profit should not be estimated solely by applying the succeeding year&#039;s gross profit rate. Estimation must be made on a fair and reasonable basis, considering the assessee&#039;s overall trading history, including accepted past results as well as the immediately succeeding year. Where the past trading results have been accepted by the department, ignoring them and relying only on the subsequent year&#039;s rate is not a proper basis for addition. The appropriate method in the stated facts was to adopt an average of the gross profit rates from the relevant past and succeeding years.</description>
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