2026 (8) TMI 1772

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.... the Income Tax Act, 1961 (hereinafter referred to as 'the Act'), dated 19.09.2025 arising out of the following respective assessment orders: * Assessment Year 2016-17: Assessment orders dated 29.03.2025 passed by the Asst Commissioner of Income Tax, Central Circle 2, Delhi (in short 'the AO') u/s 147 r.w.s. 144 of Income Tax Act, 1961(hereinafter as Act) for A.Y. 2016-17. * Assessment Year 2017-18: Assessment orders dated 28.03.2025 passed by the Asst Commissioner of Income Tax, Central Circle 2, Delhi (in short 'the AO') u/s 147 r.w.s. 144 of Income Tax Act, 1961(hereinafter as Act) for A.Y. 2017-18. 2. Since the above captioned appeals were heard together and the facts in issues are identical, the twin appeals are be....

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....ite the assessee's failure to justify the low declared GP rate of 2.03% with reliable documentary evidence. 6. Whether the Ld. CIT(A) erred in holding that the assessee was not given reasonable opportunity of being heard, whereas sufficient opportunities were provided during the assessment proceedings, including issuance of show cause notices. 7. That the appellant craves leave to add, amend, alter, or withdraw any ground(s) of appeal at the time of hearing." 4. Brief facts of the case are that the M/s Al Zia Exports Pvt. Ltd. carrying on the business of meat export to foreign countries. A survey under section 133A was conducted on 18.01.2023 at the Delhi premises of Al Zia and its group concern, M/s Al Barkat Enter....

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....mismatches were observed between purchases, exports, and closing stock. 8. Per contra, the ld AR relied on the CIT(A) and submitted that the assessee involved in the business of meat export and operates in a cash-intensive, unorganized sector, many suppliers do not issue formal bills. While most purchases are claimed to be bank-routed, a small portion is in cash, purportedly covered under Rule 6DD read with section 40A(3) of the Act. The ld AR stated that the books of account of the assessee were audited in terms of section 44AB of the Act. 9. We have heard the rival submissions and perused the material available on record. In the instant case, we find that the assessee has shown gross profit ratio in terms of Turnover, of 2.99% in AY....