CIT v. Simit P. Sheth

356 ITR 451High Court2013#27 most cited

What is CIT v. Simit P. Sheth authority for?

Additions for alleged bogus purchases should be restricted to the profit element, not the entire turnover. The profit element is often estimated at 12.5% of the purported bogus purchases.

1,465

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2016 to 2026.

Also referred to as

CIT v. Simit P. Sheth · section 69C · bogus purchases · undisclosed income · addition on profit element · gross profit · net profit · reassessment · assessment procedure

Also reported as

38 Taxmann 385

Sections most often in play

Section 143(3)Section 147Section 148Section 132Section 131Section 69CSection 133(6)Section 143(2)

Issues it is cited on

section 69csection 131section 133(6)reassessment proceedingsundisclosed incomesearch and seizuresection 69section 132section 13section 148businesssection 147

Judgments citing CIT v. Simit P. Sheth

Co-Operation Metals, Pune vs. ITO Ward 6(3), Pune

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2321/PUN/2024[2010-11]Status: DisposedITAT Pune21 Apr 2026AY 2010-11

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

…dam & Co (2019) 103 taxmann.com 459 (Bom) 21) ITO vs. Shri Manoj Suresh Sharma vide ITA No.1645/PUN/2016 22) Laiji Jetsi Maheshwari vs. ACIT vide ITA No.860/PUN/2016 23) Shri Ashwin Purushottam Bajaj vs. ITO vide ITA No.4736/Mum/2014 24) CIT vs. Simit P Sheth 356 ITR 451 (Guj) 25) Shri Madhukant B Gandhi vs. ITO vide ITA No.1950/Mum/2009 9. We have heard the rival arguments made by both the sides, perused the orders of the Assessing Officer and Ld. CIT(A) / NFAC and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us. We find the Assessing Officer in the…

Co-Operation Metals, Pune vs. ITO Ward 6(3), Pune

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2320/PUN/2024[2011-12]Status: DisposedITAT Pune21 Apr 2026AY 2011-12

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

…dam & Co (2019) 103 taxmann.com 459 (Bom) 21) ITO vs. Shri Manoj Suresh Sharma vide ITA No.1645/PUN/2016 22) Laiji Jetsi Maheshwari vs. ACIT vide ITA No.860/PUN/2016 23) Shri Ashwin Purushottam Bajaj vs. ITO vide ITA No.4736/Mum/2014 24) CIT vs. Simit P Sheth 356 ITR 451 (Guj) 25) Shri Madhukant B Gandhi vs. ITO vide ITA No.1950/Mum/2009 9. We have heard the rival arguments made by both the sides, perused the orders of the Assessing Officer and Ld. CIT(A) / NFAC and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us. We find the Assessing Officer in the…

Co-Operation Metals, Pune vs. ITO Ward 6(3), Pune

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2319/PUN/2024[2009-10]Status: DisposedITAT Pune21 Apr 2026AY 2009-10

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

…dam & Co (2019) 103 taxmann.com 459 (Bom) 21) ITO vs. Shri Manoj Suresh Sharma vide ITA No.1645/PUN/2016 22) Laiji Jetsi Maheshwari vs. ACIT vide ITA No.860/PUN/2016 23) Shri Ashwin Purushottam Bajaj vs. ITO vide ITA No.4736/Mum/2014 24) CIT vs. Simit P Sheth 356 ITR 451 (Guj) 25) Shri Madhukant B Gandhi vs. ITO vide ITA No.1950/Mum/2009 9. We have heard the rival arguments made by both the sides, perused the orders of the Assessing Officer and Ld. CIT(A) / NFAC and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us. We find the Assessing Officer in the…

Income Tax Officer, Pune vs. Cooperation Metals, Pune

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2263/PUN/2024[2011-12]Status: DisposedITAT Pune21 Apr 2026AY 2011-12

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

…dam & Co (2019) 103 taxmann.com 459 (Bom) 21) ITO vs. Shri Manoj Suresh Sharma vide ITA No.1645/PUN/2016 22) Laiji Jetsi Maheshwari vs. ACIT vide ITA No.860/PUN/2016 23) Shri Ashwin Purushottam Bajaj vs. ITO vide ITA No.4736/Mum/2014 24) CIT vs. Simit P Sheth 356 ITR 451 (Guj) 25) Shri Madhukant B Gandhi vs. ITO vide ITA No.1950/Mum/2009 9. We have heard the rival arguments made by both the sides, perused the orders of the Assessing Officer and Ld. CIT(A) / NFAC and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us. We find the Assessing Officer in the…

Income Tax Officer, Pune vs. Cooperation Metals, Pune

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2262/PUN/2024[2009-10]Status: DisposedITAT Pune21 Apr 2026AY 2009-10

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

…dam & Co (2019) 103 taxmann.com 459 (Bom) 21) ITO vs. Shri Manoj Suresh Sharma vide ITA No.1645/PUN/2016 22) Laiji Jetsi Maheshwari vs. ACIT vide ITA No.860/PUN/2016 23) Shri Ashwin Purushottam Bajaj vs. ITO vide ITA No.4736/Mum/2014 24) CIT vs. Simit P Sheth 356 ITR 451 (Guj) 25) Shri Madhukant B Gandhi vs. ITO vide ITA No.1950/Mum/2009 9. We have heard the rival arguments made by both the sides, perused the orders of the Assessing Officer and Ld. CIT(A) / NFAC and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us. We find the Assessing Officer in the…

Income Tax Officer, Pune vs. Cooperation Metals, Pune

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2271/PUN/2024[2010-11]Status: DisposedITAT Pune21 Apr 2026AY 2010-11

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

…dam & Co (2019) 103 taxmann.com 459 (Bom) 21) ITO vs. Shri Manoj Suresh Sharma vide ITA No.1645/PUN/2016 22) Laiji Jetsi Maheshwari vs. ACIT vide ITA No.860/PUN/2016 23) Shri Ashwin Purushottam Bajaj vs. ITO vide ITA No.4736/Mum/2014 24) CIT vs. Simit P Sheth 356 ITR 451 (Guj) 25) Shri Madhukant B Gandhi vs. ITO vide ITA No.1950/Mum/2009 9. We have heard the rival arguments made by both the sides, perused the orders of the Assessing Officer and Ld. CIT(A) / NFAC and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us. We find the Assessing Officer in the…

Nitin Mangla, Delhi vs. PCIT-15, Delhi

In the result, appeal of the assessee is allowed

ITA 2693/DEL/2025[2021-22]Status: DisposedITAT Delhi10 Apr 2026AY 2021-22

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2021-22] Nitin Mangla Vs Pcit-15 D-15, Ground Floor, Delhi Vikaspuri, New Delhi- 110018. Pan-Ajbpm5834C Appellant Respondent Appellant By Shri Shantanu Kanungo, Adv. & Ms. Sayantani Kanungo, Adv. Respondent By Ms. Pooja Swaroop, Cit Dr Date Of Hearing 22.01.2026 Date Of Pronouncement 10.04.2026

Section 132Section 133(6)Section 142(1)Section 143(2)Section 263Section 69C

…five parties remained un-complied therefore, the AO hold the total purchase made from these Five parties at INR 10,47,03,730/- as not genuine and bogus and by following the judgment of Hon’ble Gujarat High Court in the case of CIT vs Simit P Sheth reported in 356 ITR 451 (Guj. HC) made the addition @ 12.5% of total purchases held as bogus and made the addition of INR 1,30,87,966/- u/s 69C of the Act. The total income of the assessee thus, was computed at INR 1,45,26,090/-. Thereafter, Ld. PCIT initiated the revision proceedings u/s 263 of the Act by issue of show cause notice dated 03.03.2025 wherein Ld. PCIT obs…

Income Tax Officer 41(1)(1), Mumbai vs. Anil Transport Service, Mumbai

In the result, the appeal of the revenue bearing ITA No

ITA 5435/MUM/2025[2009]Status: DisposedITAT Mumbai07 Apr 2026

Bench: Shri Anikesh Banerjee & Ito 41(1)(1), Mumbai Vs Anil Transport Service Room No.830, Kautilya B-102, Harshad Apartment, E.E. Bhavan, Bkc, Bandra East Highway Behind Everad Nagar Sion Mumbai-400051 East, Mumbai-400022 Pan: Aalfa8944J Appellant Respondent Co No.90/Mum/2026 (Assessment Year: 2009-10) Anil Transport Service Vs Ito 41(1)(1) B-102, Harshad Apartment, Room No.830, Kautilya Bhavan, E.E. Highway Behind Everad Bkc, Bandra East Mumbai-400051 Nagar Sion East, Mumbai- 400022 Pan: Aalfa8944J Appellant Respondent Assessee By : Shri C.V.Dharkar Revenue By : Shri Surendra Mohan (Sr. Dr) Date Of Hearing : 01/04/2026 Date Of Pronouncement : 07/04/2026

For Appellant: Shri C.V.DharkarFor Respondent: Shri Surendra Mohan (Sr. DR)
Section 131Section 143(3)Section 250

…hases from the eight parties could not be added as bogus, but what needed to be taxed is the profit element embedded in such transaction. Following Gujarat High Court decision in the case of CIT v. Simit P. Sheth [2013] 38 taxmann.com 385/219 Taxman 85 (Mag.)/356 ITR 451 (Guj.), CIT(A) vide its appellate order dated 18th August, 2014 took the view that the estimation of 17.5% of profit would meet the ends of justice. Accordingly, direction was issued to the Assessing Officer. 8. In appeal before the Tribunal by the Revenue, Tribunal held that there was no reason to intervene in the finding of the CIT(A) which was…

Deputy Commissioner of Income Tax, Delhi vs. Malhotra Cables Pvt Ltd, Delhi

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1324/DEL/2025[2023-24]Status: DisposedITAT Delhi11 Mar 2026AY 2023-24

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…e gross profit for various assessment years. This action was condemned by the Learned CIT(A) and gross profit percentage was reduced by Learned CIT(A) to 12.5% based on the decision of Hon’ble Gujarat High Court in the case of CIT vs Simit P Sheth reported in 356 ITR 451 (Guj) and CIT vs Bholanath Polyfab P Ltd reported in 355 ITR 290 (Guj), among other decisions. 11. We find that the assessee had in the revised computation of income for various assessment years had further claimed deduction on account of business promotion expenses of Rs 5,84,67,950 and other business related expenses of Rs 1,63,97,796. The sub…

Deputy Commissioner of Income Tax, Delhi vs. Malhotra Cables Pvt Ltd, Delhi

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1323/DEL/2025[2022-23]Status: DisposedITAT Delhi11 Mar 2026AY 2022-23

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…e gross profit for various assessment years. This action was condemned by the Learned CIT(A) and gross profit percentage was reduced by Learned CIT(A) to 12.5% based on the decision of Hon’ble Gujarat High Court in the case of CIT vs Simit P Sheth reported in 356 ITR 451 (Guj) and CIT vs Bholanath Polyfab P Ltd reported in 355 ITR 290 (Guj), among other decisions. 11. We find that the assessee had in the revised computation of income for various assessment years had further claimed deduction on account of business promotion expenses of Rs 5,84,67,950 and other business related expenses of Rs 1,63,97,796. The sub…

Deputy Commissioner of Income Tax, Delhi vs. Malhotra Cables Pvt Ltd, Delhi

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1322/DEL/2025[2021-22]Status: DisposedITAT Delhi11 Mar 2026AY 2021-22

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…e gross profit for various assessment years. This action was condemned by the Learned CIT(A) and gross profit percentage was reduced by Learned CIT(A) to 12.5% based on the decision of Hon’ble Gujarat High Court in the case of CIT vs Simit P Sheth reported in 356 ITR 451 (Guj) and CIT vs Bholanath Polyfab P Ltd reported in 355 ITR 290 (Guj), among other decisions. 11. We find that the assessee had in the revised computation of income for various assessment years had further claimed deduction on account of business promotion expenses of Rs 5,84,67,950 and other business related expenses of Rs 1,63,97,796. The sub…

Deputy Commissioner of Income Tax, Delhi vs. Malhotra Cables Pvt Ltd, Delhi

In the result, all the appeals of the assessee as well as the revenue

ITA 1321/DEL/2025[2020-21]Status: DisposedITAT Delhi11 Mar 2026AY 2020-21

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri Tarun Chanana, Adv
Section 143(3)Section 148Section 149(1)(b)

…e gross profit for various assessment years. This action was condemned by the Learned CIT(A) and gross profit percentage was reduced by Learned CIT(A) to 12.5% based on the decision of Hon'ble Gujarat High Court in the case of CIT vs Simit P Sheth reported in 356 ITR 451 (Guj) and CIT vs Bholanath Polyfab P Ltd reported in 355 ITR 290 (Guj), among other decisions. 11. We find that the assessee had in the revised computation of income for various assessment years had further claimed deduction on account of business promotion expenses of Rs 5,84,67,950 and other business related expenses of Rs 1,63,97,796. The subm…

Deputy Commissioner of Income Tax, Delhi vs. Malhotra Cables Pvt Ltd, Delhi

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1320/DEL/2025[2019-20]Status: DisposedITAT Delhi11 Mar 2026AY 2019-20

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…e gross profit for various assessment years. This action was condemned by the Learned CIT(A) and gross profit percentage was reduced by Learned CIT(A) to 12.5% based on the decision of Hon’ble Gujarat High Court in the case of CIT vs Simit P Sheth reported in 356 ITR 451 (Guj) and CIT vs Bholanath Polyfab P Ltd reported in 355 ITR 290 (Guj), among other decisions. 11. We find that the assessee had in the revised computation of income for various assessment years had further claimed deduction on account of business promotion expenses of Rs 5,84,67,950 and other business related expenses of Rs 1,63,97,796. The sub…

Deputy Commissioner of Income Tax, Delhi vs. Malhotra Cables Pvt Ltd, Delhi

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1319/DEL/2025[2018-19]Status: DisposedITAT Delhi11 Mar 2026AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…e gross profit for various assessment years. This action was condemned by the Learned CIT(A) and gross profit percentage was reduced by Learned CIT(A) to 12.5% based on the decision of Hon’ble Gujarat High Court in the case of CIT vs Simit P Sheth reported in 356 ITR 451 (Guj) and CIT vs Bholanath Polyfab P Ltd reported in 355 ITR 290 (Guj), among other decisions. 11. We find that the assessee had in the revised computation of income for various assessment years had further claimed deduction on account of business promotion expenses of Rs 5,84,67,950 and other business related expenses of Rs 1,63,97,796. The sub…

Deputy Commissioner of Income Tax, Delhi vs. Malhotra Cables Pvt Ltd, Delhi

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1318/DEL/2025[2017-18]Status: DisposedITAT Delhi11 Mar 2026AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…e gross profit for various assessment years. This action was condemned by the Learned CIT(A) and gross profit percentage was reduced by Learned CIT(A) to 12.5% based on the decision of Hon’ble Gujarat High Court in the case of CIT vs Simit P Sheth reported in 356 ITR 451 (Guj) and CIT vs Bholanath Polyfab P Ltd reported in 355 ITR 290 (Guj), among other decisions. 11. We find that the assessee had in the revised computation of income for various assessment years had further claimed deduction on account of business promotion expenses of Rs 5,84,67,950 and other business related expenses of Rs 1,63,97,796. The sub…

Deputy Commissioner of Income Tax, Delhi vs. Malhotra Cables Pvt Ltd, Delhi

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1317/DEL/2025[2016-17]Status: DisposedITAT Delhi11 Mar 2026AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…e gross profit for various assessment years. This action was condemned by the Learned CIT(A) and gross profit percentage was reduced by Learned CIT(A) to 12.5% based on the decision of Hon’ble Gujarat High Court in the case of CIT vs Simit P Sheth reported in 356 ITR 451 (Guj) and CIT vs Bholanath Polyfab P Ltd reported in 355 ITR 290 (Guj), among other decisions. 11. We find that the assessee had in the revised computation of income for various assessment years had further claimed deduction on account of business promotion expenses of Rs 5,84,67,950 and other business related expenses of Rs 1,63,97,796. The sub…

Malhotra Cables Private Limited, New Delhi vs. DCIT, Centra Circle - 7, New Delhi

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1108/DEL/2025[2019-20]Status: DisposedITAT Delhi11 Mar 2026AY 2019-20

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…e gross profit for various assessment years. This action was condemned by the Learned CIT(A) and gross profit percentage was reduced by Learned CIT(A) to 12.5% based on the decision of Hon’ble Gujarat High Court in the case of CIT vs Simit P Sheth reported in 356 ITR 451 (Guj) and CIT vs Bholanath Polyfab P Ltd reported in 355 ITR 290 (Guj), among other decisions. 11. We find that the assessee had in the revised computation of income for various assessment years had further claimed deduction on account of business promotion expenses of Rs 5,84,67,950 and other business related expenses of Rs 1,63,97,796. The sub…

Malhotra Cables Private Limited, New Delhi vs. DCIT, Central Circle -7, New Delhi

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1107/DEL/2025[2020-21]Status: DisposedITAT Delhi11 Mar 2026AY 2020-21

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…e gross profit for various assessment years. This action was condemned by the Learned CIT(A) and gross profit percentage was reduced by Learned CIT(A) to 12.5% based on the decision of Hon’ble Gujarat High Court in the case of CIT vs Simit P Sheth reported in 356 ITR 451 (Guj) and CIT vs Bholanath Polyfab P Ltd reported in 355 ITR 290 (Guj), among other decisions. 11. We find that the assessee had in the revised computation of income for various assessment years had further claimed deduction on account of business promotion expenses of Rs 5,84,67,950 and other business related expenses of Rs 1,63,97,796. The sub…

Malhotra Cables Private Limited, New Delhi vs. DCIT, Central Circle -7, New Delhi

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1102/DEL/2025[2023-24]Status: DisposedITAT Delhi11 Mar 2026AY 2023-24

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…e gross profit for various assessment years. This action was condemned by the Learned CIT(A) and gross profit percentage was reduced by Learned CIT(A) to 12.5% based on the decision of Hon’ble Gujarat High Court in the case of CIT vs Simit P Sheth reported in 356 ITR 451 (Guj) and CIT vs Bholanath Polyfab P Ltd reported in 355 ITR 290 (Guj), among other decisions. 11. We find that the assessee had in the revised computation of income for various assessment years had further claimed deduction on account of business promotion expenses of Rs 5,84,67,950 and other business related expenses of Rs 1,63,97,796. The sub…

Malhotra Cables Private Limited, New Delhi vs. DCIT, Central Circle - 7, New Delhi

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1097/DEL/2025[2021-22]Status: DisposedITAT Delhi11 Mar 2026AY 2021-22

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…e gross profit for various assessment years. This action was condemned by the Learned CIT(A) and gross profit percentage was reduced by Learned CIT(A) to 12.5% based on the decision of Hon’ble Gujarat High Court in the case of CIT vs Simit P Sheth reported in 356 ITR 451 (Guj) and CIT vs Bholanath Polyfab P Ltd reported in 355 ITR 290 (Guj), among other decisions. 11. We find that the assessee had in the revised computation of income for various assessment years had further claimed deduction on account of business promotion expenses of Rs 5,84,67,950 and other business related expenses of Rs 1,63,97,796. The sub…