TaxTMI 
TaxTMI 
2025 (3) TMI 1791
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....1961. 2. Grounds of appeals: 1. The grounds of appeal mentioned hereunder are without prejudice to one another. 2. The Id. Commissioner of Income-tax (Appeals), National Faceless Appeal Centre, Delhi [hereinafter referred to as the "CIT(A)"] erred on facts as also in law in confirming the action of the AO in rejecting books of account and estimation of gross profit @ 6.86% as against 4.47% shown by the appellant and thereby making an addition of Rs. 30,94,464/- on turnover of Rs. 12,94,75,482/-. The addition confirmed by the learned CIT(A) is totally unjustified on facts as also in law and may kindly be deleted. 3. Your Honour's appellant craves leave to add, to amend, alter, or withdraw any or more grounds....
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....olding etc. and as such the work has been done as per the latest fashion. Since the one cloth has to pass through multiple people for different work on one piece of kapitan, the person to whom payment made has also to get the services of other people to complete the job. As such interpretation that the description is not mentioned in the bills. Payments made by the persons covered u/s 40A(2)(b) for getting various work through outsiders have also been made available to the AO along with their ITR. Since the parties to whom raised bills are in conformity with the work assigned to them and the bills have been followed by payments duly supported. The payment for job work on one piece of item is passing through various procedures like ....
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....e total income of the assessee, is as under. Total income as per return of income Rs. 8,65,370/- (i)Addition on a/c of G.P. Estimation Rs. 30,94,464/- Assessed Total Income Rs. 39,59,834/- Rounded off to Rs. 39,59,830/- 5. The assessee has filed an appeal before the Ld CIT(A). The Ld CIT(A) as disposed of the appeal by order dated 01/12/2023. The AO has taken up genuine and justified approach towards estimating the GP rate based on last three years results of the Gross profit shown by the appellant. Accordingly I hereby confirm the addition of Rs. 30,94,464/- made by the AO on account of estimated gross profit for the year under consideration. Therefore these grounds of appeal are dismissed. 6 The asse....
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....sal product from plain cloth. It depends on the fashion and the work done thereon. The entire process of manufacturing Kapital through job-work is duly recorded in the audited books of accounts and the Audit report. (iii) We further note that complex process of manufacturing detail submitted by the assessee supra handwork on kaftan includes several types of work on the same cloth like, iron, folding after iron, stitching (stitching includes pearls, jaree, satari, stone, hallmark etc.), etc. Sometime the assessee has given a single type of works to some parties on job-work basis. Sometime the assessee has given bulk types of work like, iron, folding after iron, stitching, to single party on job-work basis. By and large bulk works gi....
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.... 13) where in it was mentioned that Gross Profit Margin is declined due to competition prevailing in the market so firm has applied the policy to do business with lower margin and also there is increase in the cost of purchase and major direct expense i.e. labour expense because some time it may happen that work is not there due to recession and we have to paid Idle for labour expenses, further there is increase in labour cost also due to shortage of labour forces. 10 Thus, before rejecting the books of account the AO is duty bound to record the satisfaction that the assessee has not fulfilled the requirements of section 145 of the Act. Any single specific defect or discrepancy in the books of account, any instance of suppression of sale....