SHRI RASHID AHMED BEIGH,JAMMU vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, JAMMU

ITA 419/ASR/2025Status: HeardITAT Amritsar08 September 2026AY 2021-223 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal noted that previous assessment years showed profit rates between 1.84% and 3.95%. Considering this, the Tribunal directed the Assessing Officer to apply a profit rate of 3% on the assessee's turnover.

What were the facts?

The assessee's group was searched, and the assessment for AY 2021-22 was framed on a best judgment basis. The Assessing Officer estimated a 7% profit rate on a turnover of Rs. 26.90 Crores. The CIT(A) reduced this to 6.5%.

What were the issues?

The primary issue was the reasonableness of the profit rate estimated by the Assessing Officer and confirmed by the CIT(A) in a best judgment assessment, considering past profit margins.

Which sections of the Income-tax Act were involved?

Section 144,Section 153A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “DB” BENCH, AMRITSAR

Before: HON’BLE SHRI LALIET KUMAR, JM & HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM

Manoj Kumar Aggarwal (Accountant Member)

1.

Aforesaid appeal by assessee for Assessment Year (AY) 2021-22 arises out of an order of learned Commissioner of Income Tax (Appeals)-5, Ludhiana [CIT(A)] dated 26.03.2025 in the matter of an assessment framed by Ld. Assessing Officer [AO] on best judgment basis u/s 144 of the Act on 22.11.2022. 2. It emerges that the assessee group was subjected to search on 06.01.2021. The assessee is stated to be eng

The order continues below.

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