2026 (7) TMI 553

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....h. Manoj Kumar, Sr. DR ORDER PER VIKAS AWASTHY, JUDICIAL MEMBER : These two appeals by the assessee are directed against the orders of Commissioner of Income Tax (Appeals), Lucknow-3 [in short 'the CIT(A)'] for Assessment Years 2019-20 & 2020-21, respectively. Both the impugned orders are of even date i.e. 26.02.2026. 2. Shri K.R. Rastogi, appearing on behalf of the assessee submits th....

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.... Thus, restricting the addition to Rs. 25,64,374/-. The ld. Counsel submits that in the case of Sushil Kumar Garg, the AO under identical set of facts has made addition @1.78%. He stated that the addition @8% is very much on the higher side and prayed for restricting it to the GP already declared by the assessee i.e. 1.61% on the undisclosed sales. 3. Per contra, Shri Manoj Kumar, representing ....

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....showing that the average GP of the assessee of the two preceding and two succeeding assessment years comes to 1.35%. Considering entire facts of the case and to meet the ends of justice, GP addition @2% is estimated. The AO is directed to restrict the addition to 2% of total purchases. ITA No. 4575/Del/2026 (AY 2020-21) 5. The ld. Counsel for the assessee submits that the facts in the impugn....