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2025 (4) TMI 2138

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....n filed by the Assessee against the order dated 07.11.2024 passed by the NFAC, Delhi for the assessment year 2017-18. 2. Heard both the parties at length and perused the relevant records. 3. It is noted that AO estimated the business profit of Rs. 6,65,075/- being 8% of accepted turnover of Rs. 83,13,342/- and not accepted Rs. 16,62,487/- as turnover of the assessee. AO also invoked provisio....

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....s. 6,65,075/- being 8% of accepted turnover of Rs. 83,13,342/-, which needs to be deleted. He further submitted that the AO had also invoked Section 115BBE of the Act, which is contrary to the decision of the Madras High Court in the case of Smile Microfinance Ltd. WP(MD) No. 2078/2020 and 1742/2020 dated 19.11.2024, wherein it has been held that the law applied to the transactions on or after 1.4....

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....ies and perused thee records. I have given my thoughtful consideration to the assessee's arguments and Revenue's contention in support of the impugned addition. I find no reason to accept either parties stand in entirety. This is for the precise reason that neither the assessee has been able to properly explain the source of cash deposits nor the department could simply brush aside all the relevan....