2025 (10) TMI 524

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....ase file perused. 3. The assessee pleads the following substantive grounds in the instant appeal: "1. BECAUSE, the Ld. "CIT (APPEALS)" has erred in law and on facts in sustaining the addition of Rs. 45,25,459/- as against the returned income of Rs. 6,40,760/- by the assessee. 2. BECAUSE, the Ld. "CIT (APPEALS)" has erred to take into consideration that the Ld. AO has wrongly been taken the base of GP Ratio of other dealers on the National Highway/City to reject the accounts book of the assessee. The Gross Turnover/GP Ratio/NP Ratio of the business depends on the locality, commission rate, transportation, handling loss and many other factors in relation to where the petrol pump is situated. The assessee petrol pump is ab....

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....the price of petrol was at Rs. 66.45/- on 31.03.2012 and price of Diesel and Petrol was Rs. 47.23/- and Rs. 69.22/- respectively on 31.03.2013. 4. BECAUSE, the Ld. "CIT (APPEALS)" has erred to take into consideration that the Ld. AO has wrongly added the amount of Rs. 1,08,000/- on account of salary expenses of working partners paid during the year to the partners as the said amount was already added in the order u/s 143(1) of the Income Tax Act, 1961. The AO has repeated the addition of Rs. 1,08,000/- even when notified by the assesses that the same amount has already been added in the order u/s 143(1) of the Income Tax Act, 1961. 5. BECAUSE, the Ld. "CIT (APPEALS)" has erred to take into consideration that the Ld. AO has....