2025 (12) TMI 798

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....Respondent : Ms. Gauthami Manivasagam, JCIT ORDER PER MANU KUMAR GIRI, JM: The captioned appeal by the assessee is arising out of the order of the Ld. Commissioner of Income Tax (Appeals)/NFAC, Delhi dated 27.01.2025 for AY 2013-14. 2. We find that this appeal is filed with a delay of 155 days. The assessee filed an affidavit for condonation of delay stating the reasons. Upon hearing b....

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.... advertisement services through various mediums including newspaper advertisements. It has been submitted by ld.AR that the assessee operates on a thin-margin model, as demonstrated by historical financial results. During the Assessment Year under consideration, the assessee disclosed contract receipts of Rs. 8,40,12,821/- and earned net profit of Rs. 28,72,757/- resulting in a profit ratio of 3.4....

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....years is not justified. The ld. AR further pleaded that there is a double addition regarding cash deposits, which the assessee submits is part of business receipts already considered. The ld.AR vehemently submitted that the ld.CIT(A) has failed to appreciate that the assessee's financials and IDS declaration support a net profit margin in the range of 3%-4%, and estimation beyond that is unjustifi....

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....ecord to disprove the assessee's claim or to justify an unusually high profit rate such as 25% or even 8%. The profit declared under IDS is consistent with audited financials and further reinforces the assessee's claim of low margins. We also note that the AO has not brought any comparable market data, industry benchmarks, instances of inflation of expenses, or defects in financials that justify a....