2020 (6) TMI 529

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....d its return of income for the year under consideration on 01.07.14 declaring a total income of Rs. 4,91,830/- and return was processed u/s 143(1) of the I.T. Act. Thereafter the case was selected for scrutiny and notices u/s 143(2) and 142(1) were served upon the assessee. In response, AR of the assessee attended and furnished the details as called from time to time. 3. During the assessment proceeding, AO observed that assessee has disclosed the total sales at Rs. 1,75,82,560/- and the relevant purchases at Rs. 1,56,66,543 and net profit at Rs. 7,10,280/-. He further observed that AIR information was available on record which shows that assessee has deposited cash of Rs. 57,71,930/- in his saving banks. On further enquiry, considering th....

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....riginal return of income. 5. Now before us, the assessee has preferred the appeal against the order of Ld. CIT(A) on the grounds mentioned below:- 1. On the facts and circumstances of the case and law, the Ld. CIT(A) erred in confirming rejection of books of account u/s 145(3) of Income Tax Act, 1961. 2. On the facts and circumstances of the case and law, the Ld. CIT(A) erred in confirming suppress gross profit margin @11% which is abnormally high and against the prevailing GP rate in milk distribution business and required to be reduced. 3. Assessee craves leave to reserve right to add to, alter or amend any of the aforesaid grounds of appeal at or before the time of hearing and to produce such further evidence, documents and papers....

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....ties and submitted that the results declared by the assessee are not reliable and supported the findings of revenue authorities by considering the peculiar facts of this case. 9. Considered the rival submission and material placed on record, we notice from the record that assessee is a milk supplier and purchases milk from Swaraj India Industries Ltd, Shree Warna Sahakari Dudh Utpadak Prakiya Sangh Ltd, etc. and its main source of income only a commission income on sales of above milks. Assessee has submitted a detail chart on earning of commission from milk producers, which is ranging from Rs. 1.40 to 0.90 i.e. on an average earned 4.3%. We notice that assessee has declared GP 5.93% and 6.3% in earlier AYs 2011-12 and 2012-13 respectively....