CIT v. Samir Synthetics Mill

326 ITR 410High Court2010#1980 most cited

What is CIT v. Samir Synthetics Mill authority for?

When undisclosed sales or receipts are detected, income tax addition should be limited to the estimated profit embedded in such unaccounted transactions, rather than the entire gross value of the sales. This approach implicitly accounts for the cost component of goods sold and prevents distorted profit ratios.

58

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2011 to 2026.

Also referred to as

Samir Synthetics Mill · 326 ITR 410 · unaccounted sales taxability · undisclosed receipts addition · profit on unaccounted sales · Section 153A · Section 115BBE · Section 69C · estimated profit · gross turnover addition · unexplained income · Gujarat High Court

Issues it is cited on

Judgments citing CIT v. Samir Synthetics Mill

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. GAURANG ALLOYS AND IRON LIMITED, KOLKATA

In the result, the appeal of the revenue is dismissed

ITA 1257/KOL/2025[2020-21]Status: DisposedITAT Kolkata23 Dec 2025AY 2020-21

Bench: Shri Rajesh Kumar, Accountantmember & Shri Pradip Kumar Choubey, Judicialmember Assessment Year: 2020-21 Dcit, Central Circle-4(3), Kolkata…....………..............................……….……Appellant Vs. Gaurang Alloys & Iron Ltd...………….……………………...……...…..…..Respondent 402A, Mangalam, 24/26, Hemanta Basu Sarani, Kol-1.. [Pan: Aaccg1485A] Appearances By: Dr. Anup Biswas, Cit-Dr,Appeared On Behalf Of The Appellant. Shri S. Jhajharia, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 30, 2025 Date Of Pronouncing The Order :December 23, 2025 Order Per Rajesh Kumar: This Is An Appeal Preferred By The Revenue Against The Order Of The Cit(Appeals)-27, Kolkata (Hereinafter Referred To As The “Ld. Cit(A)”] Dated 25.02.2025Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’)For The Ay 2020-21. 2. The Only Issue Raised By The Revenue In This Appeal Is Against The Order Of Ld. Cit(A) Treating The Undisclosed Cash Sales/Receipts Of Rs.7,54,07,283/- As Business Transaction & Directing The Ao To Apply G.P Rate @ 6.5% To Determine The Profit From The Undisclosed Sales/Receipts.

Section 132(1)Section 139(1)Section 143(1)Section 153ASection 250Section 68

…hegoods which have been sold has been made by the assessee and that has also not beendisclosed, such addition could not be sustained.” 6.2.7. Further I rely on the decision in the case of ‘Commissioner of Income Tax v. SamirSynthetics Mill, reported in (2010) 326 ITR 410’, wherein the Hon’ble Gujrat High Courtconfirmed the view of the Tribunal accepting only the profit of unaccounted sale for thepurpose of collecting tax. 6.2.8. In the case of ‘PR. Commissioner of Income Tax-2 Vs. Rameshwar Textile MillsLtd’ ITA 527 & 528 of 2015’, the Hon’ble Gujrat High Court had held the following: 4 Gaurang Alloys and Iron Lt…

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CIT v. Samir Synthetics Mill (326 ITR 410) — Cited in 58 Judgments | BharatTax