2. Kachwala Gems v. CIT

206 CTR 585Supreme Court of India2006#6417 most cited
18

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2018 to 2025.

Sections most often in play

Section 143(3)Section 144Section 153ASection 115BBESection 132Section 132(1)Section 132(3)Section 132(4)

Issues it is cited on

set off of lossesretraction of statementrejection of books of accountsection 127rule 46aaddition u/s 68section 131double taxationunexplained cash creditaccommodation entrysection 133section 133a

Judgments citing 2. Kachwala Gems v. CIT

SUNIL KUMAR AGARWAL,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR

ITA 521/JPR/2025[2020-21]Status: DisposedITAT Jaipur14 Oct 2025AY 2020-21

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, \nvk;dj vihy la-@ITA Nos.513 & 519 to 521/JP/2025\nfu/k Zkj.k o\"kZ@Assessment Years : 2016-17 & 2018-19 to 2020-21\n\nSunil Kumar Agarwal\n395, Narnoli Mansion, Outside\nSanganeri Gate, Jaipur\ncuke\nVs.\nACIT,\nCentral Circle-2,\nJaipur\nLFkk;h y s[kk l a-@thvkb Zvkj la-@PAN/GIR No.: ABRPA9601M\nvihykFkhZ@Appellant i zR;Fkh Z@Respondent\n\nvk;dj vihy la-@ITSS No. 03/JP/2025\nfu/k Zkj.k o\"kZ@Assessment Year : 2015-16\

For Appellant: Shri S. L. Poddar, AdvFor Respondent: Mrs. Anita Rinesh, JCIT, Sr-DR
Section 132Section 139Section 153ASection 234B

…High Court cannot substitute its best\njudgment for that of the assessing authority.\"\nIt is held by the Hon'ble Supreme Court in the case of Kachwala Gems vs. Joint\nCommissioner of Income-tax, Jaipur [2007] 158 Taxman 71 (SC)/[2007] 288 ITR\n10 (SC)/[2006] 206 CTR 585 (SC) (14-12-2006] as under:-\n\"11. It is well-settled that in a best judgment assessment, there is always a\ncertain degree of guess work. No doubt the authorities concerned should try to\nmake an honest and fair estimate of the income even in a best judgment\nassessment, and should not act totally arbitrarily, but there is necessarily some\namo…

SUNIL KUMAR AGARWAL,JAIPUR vs. ACIT, CEN. CIR-2, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 513/JPR/2025[2016-17]Status: DisposedITAT Jaipur14 Oct 2025AY 2016-17
For Appellant: Shri S. L. Poddar, AdvFor Respondent: Mrs. Anita Rinesh, JCIT, Sr-DR
Section 132Section 139Section 153ASection 234B

…The High Court cannot substitute its best judgment for that of the assessing authority." It is held by the Hon'ble Supreme Court in the case of Kachwala Gems vs. Joint Commissioner of Income-tax, Jaipur [2007] 158 Taxman 71 (SC)/[2007] 288 ITR 10 (SC)/[2006] 206 CTR 585 (SC) (14-12-2006] as under:- "11. It is well-settled that in a best judgment assessment, there is always a certain degree of guess work. No doubt the authorities concerned should try to make an honest and fair estimate of the income even in a best judgment assessment, and should not act totally arbitrarily, but there is necessarily some amount of…

PROFESSIONAL AUTOMOTIVES PRIVATE LIMITED,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 812/JPR/2025[2016-17]Status: DisposedITAT Jaipur23 Jul 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील /ITA Nos.809 to 815/JP/2025 निर्धारण वर्ष /Assessment Years :2013-14 to 2019-20 Professional Automotives Pvt. बनाम ACIT, Ltd. Bahu Plaza, Bahu Plaza, Jammu Vs. Central Circle- 1, and Kashmir Jaipur स्थायी लेखा सं./जी.आई.आर. सं./PAN/GIR No.:AAACP9608E अपीलार्थी/Appellant प्र]त्यर्थी/Respondent निर्धारिती की ओर से / Assessee by :Shri Tarun Mittal, CA राजस्व की ओर से /Revenue by: Shri Ajey Malik, CIT (Th. V.C)

For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

…The High Court cannot substitute its best judgment for that of the assessing authority." It is held by the Hon'ble Supreme Court in the case of Kachwala Gems vs. Joint Commissioner of Income-tax, Jaipur [2007] 158 Taxman 71 (SC)/[2007] 288 ITR 10 (SC)/[2006] 206 CTR 585 (SC)[14-12-2006] that it is well-settled that in a best judgment assessment, there is always a certain degree of guess work and it is the assessee himself who is to blame as he did not submit proper accounts. The Hon'ble Punjab and Haryana High Court in case of Tara Singh V ITO [2017] 81 taxmann.com 293 (Punjab & Haryana) held that the assessing…

SARVESH MERCANTILE PVT. LTD.,MUMBAI vs. DCIT , CC -2(1), MUMBAI

In the result, the three appeals filed by the assessee are In the result, the three appeals filed by the assessee are allowed partly for statistical allowed partly for statistical purposes

ITA 7163/MUM/2019[2013-14]Status: DisposedITAT Mumbai27 Jul 2022AY 2013-14

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2014-15 M/S Sarvesh Mercantile Pvt. Ltd., Dy. Cit Central Circle-2(4), 2Nd Floor, Johari Mansion, 259, Mumbai. Kalbadevi Road, Vs. Mumbai-400 002. Pan No. Aaics 1651 C Appellant Respondent Assessment Year: 2013-14 & Assessment Year: 2015-16 Sarvesh Mercantile Pvt. Ltd., Dcit Cc-2(1), 2Nd Floor, Johri Mansion, 259, 9Th Floor, New Pratiksha Bhavan, Kalbadevi Road, Kalbadevi, Vs. M.K. Road, Mumbai-400 002. Mumbai-400020. Pan No. Aaics 1651 C Appellant Respondent

For Appellant: NoneFor Respondent: Mrs. Neelam Shukla, CIT-DR
Section 68

…essing and interest at the rate of 11% was paid. Officer relied on the decision of the Hon’ble Supreme Court in the e decision of the Hon’ble Supreme Court in the e decision of the Hon’ble Supreme Court in the case of Kachwala Gems Gems P. Ltd. Vs JCIT (2006) 206 CTR 585(SC) Vs JCIT (2006) 206 CTR 585(SC) wherein it is held that payment by account payee cheque is not wherein it is held that payment by account payee cheque is not wherein it is held that payment by account payee cheque is not sufficient to establish the genuineness of the purchases. He further sufficient to establish the genuineness of the purchase…

SARVESH MERCANTILE PVT. LTD.,MUMBAI vs. DCIT,CC 2(1), MUMBAI

In the result, the three appeals filed by the assessee are In the result, the three appeals filed by the assessee are allowed partly for statistical allowed partly for statistical purposes

ITA 7162/MUM/2019[2015-16]Status: DisposedITAT Mumbai27 Jul 2022AY 2015-16

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2014-15 M/S Sarvesh Mercantile Pvt. Ltd., Dy. Cit Central Circle-2(4), 2Nd Floor, Johari Mansion, 259, Mumbai. Kalbadevi Road, Vs. Mumbai-400 002. Pan No. Aaics 1651 C Appellant Respondent Assessment Year: 2013-14 & Assessment Year: 2015-16 Sarvesh Mercantile Pvt. Ltd., Dcit Cc-2(1), 2Nd Floor, Johri Mansion, 259, 9Th Floor, New Pratiksha Bhavan, Kalbadevi Road, Kalbadevi, Vs. M.K. Road, Mumbai-400 002. Mumbai-400020. Pan No. Aaics 1651 C Appellant Respondent

For Appellant: NoneFor Respondent: Mrs. Neelam Shukla, CIT-DR
Section 68

…essing and interest at the rate of 11% was paid. Officer relied on the decision of the Hon’ble Supreme Court in the e decision of the Hon’ble Supreme Court in the e decision of the Hon’ble Supreme Court in the case of Kachwala Gems Gems P. Ltd. Vs JCIT (2006) 206 CTR 585(SC) Vs JCIT (2006) 206 CTR 585(SC) wherein it is held that payment by account payee cheque is not wherein it is held that payment by account payee cheque is not wherein it is held that payment by account payee cheque is not sufficient to establish the genuineness of the purchases. He further sufficient to establish the genuineness of the purchase…

SARVESH MERCANTILE P.LTD,MUMBAI vs. DCIT 2(4), MUMBAI

In the result, the three appeals filed by the assessee are In the result, the three appeals filed by the assessee are allowed partly for statistical allowed partly for statistical purposes

ITA 4634/MUM/2018[2014-15]Status: DisposedITAT Mumbai27 Jul 2022AY 2014-15

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2014-15 M/S Sarvesh Mercantile Pvt. Ltd., Dy. Cit Central Circle-2(4), 2Nd Floor, Johari Mansion, 259, Mumbai. Kalbadevi Road, Vs. Mumbai-400 002. Pan No. Aaics 1651 C Appellant Respondent Assessment Year: 2013-14 & Assessment Year: 2015-16 Sarvesh Mercantile Pvt. Ltd., Dcit Cc-2(1), 2Nd Floor, Johri Mansion, 259, 9Th Floor, New Pratiksha Bhavan, Kalbadevi Road, Kalbadevi, Vs. M.K. Road, Mumbai-400 002. Mumbai-400020. Pan No. Aaics 1651 C Appellant Respondent

For Appellant: NoneFor Respondent: Mrs. Neelam Shukla, CIT-DR
Section 68

…essing and interest at the rate of 11% was paid. Officer relied on the decision of the Hon’ble Supreme Court in the e decision of the Hon’ble Supreme Court in the e decision of the Hon’ble Supreme Court in the case of Kachwala Gems Gems P. Ltd. Vs JCIT (2006) 206 CTR 585(SC) Vs JCIT (2006) 206 CTR 585(SC) wherein it is held that payment by account payee cheque is not wherein it is held that payment by account payee cheque is not wherein it is held that payment by account payee cheque is not sufficient to establish the genuineness of the purchases. He further sufficient to establish the genuineness of the purchase…

DCIT CENTRAL CIRCLE-1(2), MUMBAI vs. M/S.SHORELINE HOTELS PRIVATE LIMITED, MUMBAI

In the result, appeals filed by the revenue as well as the Cross

ITA 2094/MUM/2018[2008-09]Status: DisposedITAT Mumbai30 Dec 2020AY 2008-09

Bench: Shri Rajesh Kumar (Am) & Shri Ram Lal Negi (Jm) Assessment Year: 2008-09 The Dy. Commissioner Of Income M/S Shoreline Hotels Pvt. Ltd., Tax, Central Circle- 1(2), Prop. M/S Marine Plaza, Dur-Ul- R. No. 906, 9Th Floor, Old Cgo Habib, 29, Marine Drive, Bldg., Annex Bldg., M.K. Road, Vs. Churchgate, Mumbai - 400020 Mumbai - 400020 Pan: Aabcs1380B

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES “G”, MUMBAI BEFORE SHRI RAJESH KUMAR (AM) AND SHRI RAM LAL NEGI (JM) Assessment Year: 2008-09 The Dy. Commissioner of Income M/s Shoreline Hotels Pvt. Ltd., Tax, Central Circle- 1(2), Prop. M/s Marine Plaza, Dur-ul- R. No. 906, 9th Floor, Old CGO habib, 29, Marine Drive, Bldg., Annex Bldg., M.K. Road, Vs. Churchgate, Mumbai - 400020 Mumbai - 400020 PAN: AABCS1380B (Appellant) (Respondent) CO No. 97/MUM/2019 (Arising out of ITA No. 2094/Mum/2018) Assessment Year: 2008-09 M/s Shoreline Hotels Pvt. Ltd., The Dy. CIT, Central Circle- 1(2), Prop. M/s Marine Plaza, D…

BHOLANATH R.SHUKLA,MUMBAI vs. ACIT CIRCLE-2, THANE

In the result, assessee’s appeals for A

ITA 4505/MUM/2018[2009-10]Status: DisposedITAT Mumbai02 May 2019AY 2009-10

Bench: Shri Shamim Yahya (Am) & Shri Ramlal Negi (Jm)

Section 133ASection 143(3)Section 147Section 148Section 68

…is unreliable does not empower the officer to make arbitrary order. On similar facts Punjab and Haryana High Court in case of C. B. Aggarwal upheld the invoking the section 145(2) and assessing income on estimate basis. Hon'ble Supreme Court in Kanchwala Gems 206 CTR 585 SC laid guidelines on rejecting the books of accounts of the assessee and also held that in a best judgment assessment there is always a certain degree of guess work. No doubt the authorities concerned should try to make an honest and fair estimate of the income even in a best judgment assessment, and should not act totally arbitrary. In Nathuram…

M/S. RAJ BUILDCON CONSTRUCTION LTD.,,GURGAON vs. JCIT, GURGAON

In the result, the appeal of the assessee is allowed partly for statistical purposes

ITA 2422/DEL/2015[2010-11]Status: DisposedITAT Delhi29 Apr 2019AY 2010-11

Bench: Shri Bhavnesh Saini & Shri O.P. Kantassessment Year: 2010-11 M/S. Raj Buildcon Vs. Jcit(A), Construction Ltd., Range-Ii, Gurgaon (Haryana) 404, Welldone Tech Park, Sector-48, Sohna Road, Gurgaon (Haryana) Pan :Aadcr6387F (Appellant) (Respondent) Appellant By Shri Rohit Tiwari, Adv. Respondent By Smt. Rinku Singh, Sr.Dr

Section 143(3)Section 145(3)Section 3

…[2011] 202 Taxman 268 (Delhi) (Copy Enclosed) where Hon’ble Delhi High Court upheld addition on account of GP rate @5% as against 3.25% disclosed by the assessee in earlier years. 4. Kachwala Gems Vs CIT [2007] 158 Taxman 71 (SC)/[2007] 288 ITR 10 (SC)/[2006] 206 CTR 585 (SC) (Copy Enclosed) Assessing Officer, on finding that assessee had not maintained and kept any quantitative details/stock register for goods traded in by it; that there was no evidence on record or document to verify basis of valuation of closing stock shown by assessee; and that GP rate declared by assessee during assessment year did not match…

DCIT, NEW DELHI vs. M/S. PEARL BOTTLING PVT. LTD., NEW DELHI

In the result, the ITA No

ITA 5306/DEL/2015[2012-13]Status: DisposedITAT Delhi27 Feb 2019AY 2012-13

Bench: Shri H.S. Sidhu & Shri L.P. Sahu

For Appellant: Sh. P.C. Yadav, AdvFor Respondent: Smt. Sulekha Verma, CIT(DR)
Section 132Section 142(1)Section 145(2)Section 153A

…111 202 Taxman 268 (Delhi) (Copy Enclosed) where Hon’ble Delhi High Court upheld addition on account of GP rate @5% as against 3.25% disclosed by the assessee in earlier years 5- Kachwala Gems Vs CIT [2007] 158 Taxman 71 (SC)/[2007] 288 ITR 10 (SC)/[2006] 206 CTR 585 (SC) (Copy Enclosed) Assessing Officer, on finding that assessee had not maintained and kept any quantitative details/stock register for goods traded in by it; that there was no evidence on record or document to verify basis of valuation of closing stock shown by assessee; and that GP rate declared by assessee during assessment year did not m…

DCIT, NEW DELHI vs. M/S. PEARL BOTTLING PVT. LTD., NEW DELHI

In the result, the ITA No

ITA 5305/DEL/2015[2011-12]Status: DisposedITAT Delhi27 Feb 2019AY 2011-12

Bench: Shri H.S. Sidhu & Shri L.P. Sahu

For Appellant: Sh. P.C. Yadav, AdvFor Respondent: Smt. Sulekha Verma, CIT(DR)
Section 132Section 142(1)Section 145(2)Section 153A

…111 202 Taxman 268 (Delhi) (Copy Enclosed) where Hon’ble Delhi High Court upheld addition on account of GP rate @5% as against 3.25% disclosed by the assessee in earlier years 5- Kachwala Gems Vs CIT [2007] 158 Taxman 71 (SC)/[2007] 288 ITR 10 (SC)/[2006] 206 CTR 585 (SC) (Copy Enclosed) Assessing Officer, on finding that assessee had not maintained and kept any quantitative details/stock register for goods traded in by it; that there was no evidence on record or document to verify basis of valuation of closing stock shown by assessee; and that GP rate declared by assessee during assessment year did not m…

KRISHNA GRAM UDYOG SAMITI,SANGRUR vs. DCIT, LUDHIANA

In the result appeal of the assessee is partly allowed for statistical

ITA 288/CHANDI/2017[2002-03]Status: DisposedITAT Chandigarh25 May 2018AY 2002-03

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

For Appellant: Sh. Deepak AggarwalFor Respondent: Dr. Gulshan Raj
Section 263

…290 CTR 361 (Delhi) (Copy Enclosed) where Hon'ble Delhi High Court, in para 22 of its order, upheld order of Hon'ble ITAT estimating GP @15% and estimating sales at Rs.1 crore. 2. Kachwala Gems Vs CIT [20071 158 Taxman 71 (SC)/r20071 288 ITR 10 (SC)/r20061 206 CTR 585 (SO (Copy Enclosed) Assessing Officer, on finding that assessee had not maintained and kept any quantitative details/stock register for goods traded in by it; that there was no evidence on record or document to verify basis of valuation of closing stock shown by assessee; and that GP rate declared by assessee during assessment year did not match…

KRISHNA GRAM UDYOG SAMITI,SANGRUR vs. DCIT, LUDHIANA

In the result appeal of the assessee is partly allowed for statistical

ITA 287/CHANDI/2017[2001-02]Status: DisposedITAT Chandigarh25 May 2018AY 2001-02

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

For Appellant: Sh. Deepak AggarwalFor Respondent: Dr. Gulshan Raj
Section 263

…290 CTR 361 (Delhi) (Copy Enclosed) where Hon'ble Delhi High Court, in para 22 of its order, upheld order of Hon'ble ITAT estimating GP @15% and estimating sales at Rs.1 crore. 2. Kachwala Gems Vs CIT [20071 158 Taxman 71 (SC)/r20071 288 ITR 10 (SC)/r20061 206 CTR 585 (SO (Copy Enclosed) Assessing Officer, on finding that assessee had not maintained and kept any quantitative details/stock register for goods traded in by it; that there was no evidence on record or document to verify basis of valuation of closing stock shown by assessee; and that GP rate declared by assessee during assessment year did not match…

M/S KRISHNA GRAM UDYOG SAMITI,SANGRUR vs. DCIT, CC-II, LUDHIANA

In the result appeal of the assessee is partly allowed for statistical

ITA 1442/CHANDI/2017[2007-08]Status: DisposedITAT Chandigarh25 May 2018AY 2007-08

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

For Appellant: Sh. Deepak AggarwalFor Respondent: Dr. Gulshan Raj
Section 263

…290 CTR 361 (Delhi) (Copy Enclosed) where Hon'ble Delhi High Court, in para 22 of its order, upheld order of Hon'ble ITAT estimating GP @15% and estimating sales at Rs.1 crore. 2. Kachwala Gems Vs CIT [20071 158 Taxman 71 (SC)/r20071 288 ITR 10 (SC)/r20061 206 CTR 585 (SO (Copy Enclosed) Assessing Officer, on finding that assessee had not maintained and kept any quantitative details/stock register for goods traded in by it; that there was no evidence on record or document to verify basis of valuation of closing stock shown by assessee; and that GP rate declared by assessee during assessment year did not match…

M/S KRISHNA GRAM UDYOG SAMITI,SANGRUR vs. DCIT, CC-II, LUDHIANA

In the result appeal of the assessee is partly allowed for statistical

ITA 1441/CHANDI/2017[2006-07]Status: DisposedITAT Chandigarh25 May 2018AY 2006-07

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

For Appellant: Sh. Deepak AggarwalFor Respondent: Dr. Gulshan Raj
Section 263

…290 CTR 361 (Delhi) (Copy Enclosed) where Hon'ble Delhi High Court, in para 22 of its order, upheld order of Hon'ble ITAT estimating GP @15% and estimating sales at Rs.1 crore. 2. Kachwala Gems Vs CIT [20071 158 Taxman 71 (SC)/r20071 288 ITR 10 (SC)/r20061 206 CTR 585 (SO (Copy Enclosed) Assessing Officer, on finding that assessee had not maintained and kept any quantitative details/stock register for goods traded in by it; that there was no evidence on record or document to verify basis of valuation of closing stock shown by assessee; and that GP rate declared by assessee during assessment year did not match…

M/S KRISHNA GRAM UDYOG SAMITI,SANGRUR vs. DCIT, CC-II, LUDHIANA

In the result appeal of the assessee is partly allowed for statistical

ITA 1440/CHANDI/2017[2005-06]Status: DisposedITAT Chandigarh25 May 2018AY 2005-06

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

For Appellant: Sh. Deepak AggarwalFor Respondent: Dr. Gulshan Raj
Section 263

…290 CTR 361 (Delhi) (Copy Enclosed) where Hon'ble Delhi High Court, in para 22 of its order, upheld order of Hon'ble ITAT estimating GP @15% and estimating sales at Rs.1 crore. 2. Kachwala Gems Vs CIT [20071 158 Taxman 71 (SC)/r20071 288 ITR 10 (SC)/r20061 206 CTR 585 (SO (Copy Enclosed) Assessing Officer, on finding that assessee had not maintained and kept any quantitative details/stock register for goods traded in by it; that there was no evidence on record or document to verify basis of valuation of closing stock shown by assessee; and that GP rate declared by assessee during assessment year did not match…

M/S KRISHNA GRAM UDYOG SAMITI,SANGRUR vs. DCIT, CC-II, LUDHIANA

In the result appeal of the assessee is partly allowed for statistical

ITA 1439/CHANDI/2017[2004-05]Status: DisposedITAT Chandigarh25 May 2018AY 2004-05

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

For Appellant: Sh. Deepak AggarwalFor Respondent: Dr. Gulshan Raj
Section 263

…290 CTR 361 (Delhi) (Copy Enclosed) where Hon'ble Delhi High Court, in para 22 of its order, upheld order of Hon'ble ITAT estimating GP @15% and estimating sales at Rs.1 crore. 2. Kachwala Gems Vs CIT [20071 158 Taxman 71 (SC)/r20071 288 ITR 10 (SC)/r20061 206 CTR 585 (SO (Copy Enclosed) Assessing Officer, on finding that assessee had not maintained and kept any quantitative details/stock register for goods traded in by it; that there was no evidence on record or document to verify basis of valuation of closing stock shown by assessee; and that GP rate declared by assessee during assessment year did not match…

M/S KRISHNA GRAM UDYOG SAMITI,SANGRUR vs. DCIT, CC-II, LUDHIANA

In the result appeal of the assessee is partly allowed for statistical

ITA 1438/CHANDI/2017[2003-04]Status: DisposedITAT Chandigarh25 May 2018AY 2003-04

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

For Appellant: Sh. Deepak AggarwalFor Respondent: Dr. Gulshan Raj
Section 263

…290 CTR 361 (Delhi) (Copy Enclosed) where Hon'ble Delhi High Court, in para 22 of its order, upheld order of Hon'ble ITAT estimating GP @15% and estimating sales at Rs.1 crore. 2. Kachwala Gems Vs CIT [20071 158 Taxman 71 (SC)/r20071 288 ITR 10 (SC)/r20061 206 CTR 585 (SO (Copy Enclosed) Assessing Officer, on finding that assessee had not maintained and kept any quantitative details/stock register for goods traded in by it; that there was no evidence on record or document to verify basis of valuation of closing stock shown by assessee; and that GP rate declared by assessee during assessment year did not match…