2026 (8) TMI 469

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....Assessee : Shri Biren Shah, AR For the Revenue : Shri Arvind Kumar Namdeo, Sr. DR ORDER PER SANJAY GARG, JUDICIAL MEMBER: The captioned appeals by the Revenue and the corresponding Cross Objections preferred by the assessee are against the separate orders of the Ld. Commissioner of Income Tax (Appeals)-12, Ahmedabad [hereinafter referred to as 'Ld. CIT(A)'] dated 26/11/2025 passed u/s.....

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....recorded, wherein, he has admitted that the assessee had not accounted for all the receipts in the books of account maintained by it. For the assessment year under consideration an amount of Rs. 3,66,68,344/- was noted as unaccounted receipts. The Assessing Officer (hereinafter referred to as "the AO"), therefore, made the addition of the said unaccounted receipts as income of the assessee. 3. ....

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.... has come in appeal contesting the action of the Ld. CIT(A) in restricting the addition to the extent of 6% only as against the addition made by the AO of the total unaccounted receipts. Whereas, the assessee in its Cross Objections has pleaded that the estimation of 6% profit element was on higher side as compared to the profit shown @ 1 to 2% in respect of the accounted for sales. 6. We have ....

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....on the overall facts and circumstances of the case, we modify the order of the Ld. CIT(A) and hold that the profit element @ 8% of the unaccounted sales should be added to the income of the assessee. We confirm the addition to that extent. 8. With the above observation, this appeal of the Revenue is partly allowed whereas Cross Objection of the assessee is hereby dismissed. ITA No. 108/Ahd/2....