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    <title>2026 (7) TMI 1977 - ITAT DELHI</title>
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    <description>Search-related assessments under Section 153C are described as valid where seized material pertains to the assessee and connects to alleged bogus sales routed through searched entities. The notes state that search evidence and subsequent enquiries supported treating those entities as accommodation-entry providers and the related sales as bogus. They further indicate that a reduced commission-rate addition without segmental comparables is excessive where the sales have already been treated as bogus. Taxable profit is therefore confined to a lump-sum gross-profit estimate of 1% or the gross-profit rate disclosed in the books, whichever is higher.</description>
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      <link>https://www.taxtmi.com/caselaws?id=796091</link>
      <description>Search-related assessments under Section 153C are described as valid where seized material pertains to the assessee and connects to alleged bogus sales routed through searched entities. The notes state that search evidence and subsequent enquiries supported treating those entities as accommodation-entry providers and the related sales as bogus. They further indicate that a reduced commission-rate addition without segmental comparables is excessive where the sales have already been treated as bogus. Taxable profit is therefore confined to a lump-sum gross-profit estimate of 1% or the gross-profit rate disclosed in the books, whichever is higher.</description>
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