Tax Officer Overlooks Business Model Change, Uses Unfounded 5% Gross Profit Rate Without Comparable Data.

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....Estimation of gross profit - There is a change in the business model of the assessee as compared to the previous year which has apparently escaped the attention of the AO where he has compared the current year results with that of the previous year and in absence of any reasonable basis for estimation of gross profit rate in form of any comparable third party data, the estimation of gross profit rate of 5% cannot be sustained....