Court Rules 10% Expense Disallowance Unfair, Suggests Lump-Sum for Realistic Profit Rate Alignment in Business Sector.

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....Disallowance being 10% of expenditure - Disallowance of expenditure @ 10% of the expenditure in the instant case appears to be on the higher side since it gives a profit rate of 37.78% which is not possible in the line of business. Considering the fact that the assessee has already declared profit rate of 9.29%, the disallowance on lumpsum basis in the instant case, in our opinion, meet the ends of justice. - AT....