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“profit element”

DisallowancesSection 69CSection 69C5,654 judgments

The decision most relied on for profit element is CIT v. President Industries (258 ITR 654), cited in 471 judgments on BharatTax.

Leading authorities on profit element

CIT v. President Industries
258 ITR 654 · 2002 · High Court
471
citing judgments

When books of account are rejected and unaccounted sales or receipts are discovered, the income addition is restricted to the net profit element embedded in these undisclosed transactions, not the entire sale proceeds or receipts, especially if corresponding purchases are not proven to be outside the books.

Sanjay Oilcake Industries v. CIT
316 ITR 274 · 2009 · High Court
460
citing judgments

In cases of alleged bogus or unverifiable purchases, rather than disallowing the entire purchase value, a reasonable profit element or a proportionate percentage of the purchases should be added back to the assessee's income.

CIT v. Siemens Aktiongesellschaft
310 ITR 320 · 2009 · High Court
259
citing judgments

Reimbursements of actual expenses without any profit element are not taxable income. Additionally, mere amendments to the Income-tax Act do not override the provisions of Double Taxation Avoidance Agreements (DTAAs).

CIT v. Vijay M. Mistry Construction Ltd.
355 ITR 498 · 2013 · High Court
252
citing judgments

In cases of alleged bogus or hawala purchases where the existence of transactions is not entirely denied, only the profit element embedded in such purchases, and not the entire purchase price, can be added to the assessee's income. The focus is on determining a reasonable profit percentage for such additions.

CIT v. Balchand Ajit Kumar
263 ITR 610 · 2003 · High Court
212
citing judgments

When making an addition for unaccounted receipts, on-money, or non-genuine purchases/sales, the addition should be restricted to the estimated profit element embedded in such transactions, rather than the entire gross amount, particularly when evidence of corresponding expenditure is incomplete. This estimation often involves applying a net profit rate.

CIT v. Gurubachhan Singh J. Juneja
302 ITR 63 · 2008 · High Court
147
citing judgments

When unaccounted receipts or suppressed sales are detected and books of account are rejected under Section 145(3), additions to income must be restricted to the profit element embedded in such transactions, not the entire transaction value. This profit element is to be estimated by considering the assessee's regular profit ratio as per books of account.

Vijay Trading Co. v. ITO
388 ITR 377 · 2016 · High Court
119
citing judgments

When purchases are found bogus, only the profit element embedded therein, and not the entire purchase value, can be added to the assessee's income.

NK Proteins Ltd. v. DCIT
292 CTR 354 · 2017 · Supreme Court
115
citing judgments

When purchases are unverifiable or alleged to be bogus, only the profit element embedded in such transactions is taxable, not the entire purchase amount; the onus lies on the assessee to prove the genuineness of the transactions.

Judgments citing profit element

Homa Engineering Works, Mumbai vs. DCIT 13(1), Mumbai

The appeal stand allowed for statistical purposes

ITA 1534/MUM/2017[2011-12]Status: DisposedITAT Mumbai05 Oct 2018AY 2011-12

Bench: Shri Manoj Kumar Aggarwal, Am & Shri Ravish Sood, Jm

For Appellant: Kishor Patel & Manali Madhwani, Ld. ARsFor Respondent: Manoj Kumar Singh, Ld. Sr. DR
Section 131Section 143(3)Section 147Section 148

appreciate that the corresponding income by way of Sales &Services having been accepted, as a natural corollary, not the entire purchases but the profit element embedded therein would be subject to tax, which in Appellant’s case only 19.43% (Gross Profit ) of the purchases of Rs.65,99,994/- ought ... factors cast a serious doubt on assessee’s claim. Therefore, in such a situation, the addition, which could be made, was to account for profit element embedded in these purchase transactions to factorize for profit earned by assessee against possible purchase of material in the grey market and undue benefit

Homa Engineering Works, Mumbai vs. DCIT 13(1), Mumbai

The appeal stand allowed for statistical purposes

ITA 1533/MUM/2017[2009-10]Status: DisposedITAT Mumbai05 Oct 2018AY 2009-10

Bench: Shri Manoj Kumar Aggarwal, Am & Shri Ravish Sood, Jm

For Appellant: Kishor Patel & Manali Madhwani, Ld. ARsFor Respondent: Manoj Kumar Singh, Ld. Sr. DR
Section 131Section 143(3)Section 147Section 148

appreciate that the corresponding income by way of Sales &Services having been accepted, as a natural corollary, not the entire purchases but the profit element embedded therein would be subject to tax, which in Appellant’s case only 19.43% (Gross Profit ) of the purchases of Rs.65,99,994/- ought ... factors cast a serious doubt on assessee’s claim. Therefore, in such a situation, the addition, which could be made, was to account for profit element embedded in these purchase transactions to factorize for profit earned by assessee against possible purchase of material in the grey market and undue benefit

Shri Rajeshkumar P. Trivedi, Mumbai vs. Income Tax Officer - 19(3)(1), Mumbai

In the result, appeal of the assessee is dismissed

ITA 1129/MUM/2018[2011-12]Status: DisposedITAT Mumbai04 Oct 2018AY 2011-12

Bench: Shri Shamim Yahya & Shri Pawan Singhshri Rajeshkumar P. Trivedi Ito - 19(3)(1) 301, Amrut Nagar, Near Jain Matru Mandir, Room No. Mandir Road, Virar (W), Vs. 202, Tardeo Road, Thane, Mumbai-401303. Mumbai-400007. Pan: Acgpt6055H Appellant Respondent

For Appellant: NoneFor Respondent: Shri Ajay Kumar Keshri (DR)
Section 133(6)Section 143(1)Section 147Section 148Section 253Section 254(1)

Officer added only 12.5% of said purchases as estimated profit earned on such purchases. The assessing officer disallowed the purchases to the extent of profit element embedded in the alleged bogus purchases on the basis of decision of Hon’ble Gujarat High Court in Simit P Sheth(supra

Sujeet Y.Singh, Mumbai vs. DCIT 30(3), Mumbai

In the result, the appeal filed by the assessee is partly allowed

ITA 1541/MUM/2017[2010-11]Status: DisposedITAT Mumbai01 Oct 2018AY 2010-11

Bench: Shri B.R. Baskaran & Shri Ravish Soodshri Sujeet Y. Singh D C I T - 30(3) Shop No. 20A, Yashodham C-10, Bandra Kurla Complex Shopping Complex Vs. Bandra (E), Mumbai, Centre Gen Ak, Goregaon (E) Mumbai Pan – Avsps5928G Appellant Respondent

For Appellant: Ms. Dinkle HariyaFor Respondent: Shri Nishant Samaiya
Section 133(6)Section 148

added the same to the total income of the assessee. 3. In the appellate proceedings, the learned CIT(A) took the view that the profit element embedded in the transactions of purchase should be assessed. For this purpose he took support of the decisions rendered by the Hon'ble Gujarat ... taxmann.com 44 (Guj) and CIT vs. Simit P. Sheth (2013) 356 ITR 451 (Guj). The learned CIT(A) took the view that the profit element embedded in the purchases can be estimated at 30%. Accordingly he sustained the addition to the extent of 30% and granted partial relied. Still Aggrieved

DCIT, Cir-22, Kolkata vs. M/S. Deloitte Haskins & Sells, Kolkata

In the result, the appeal filed by the Revenue is dismissed

ITA 651/KOL/2017[2012-13]Status: DisposedITAT Kolkata28 Sept 2018AY 2012-13

Bench: Shri S. S. Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.651/Kol/2017 ("नधा"रणवष" / Assessment Year: 2012-13) Dcit, Circle-22, Kolkata Vs. M/S. Deloitte Haskins & Sells

For Appellant: Shri A. Bhattacharjee, Addl. CITFor Respondent: Ms. Pooja Jain, Ld. AR
Section 143(3)Section 194ISection 194JSection 37(1)Section 40

Rs.48,95,212/- was towards the reimbursement of the expenses, which was in fact incurred on behalf of the assessee and there was no profit element. That being so, we decline to interfere with the order of Id. C.I T.(A) deleting the aforesaid addition. His order on this addition

ACIT 19(2), Mumbai vs. K.P. Sanghavi & Sons, Mumbai

In the result, both appeal of the Revenue and Cross Objection of the assessee are dismissed

ITA 2455/MUM/2017[2011-12]Status: DisposedITAT Mumbai28 Sept 2018AY 2011-12

Bench: Shri C.N. Prasad, Hon'Ble & Shri N.K. Pradhan, Hon'Blea.C.I.T Circle – 19(2) V. M/S. K.P. Sanghvi & Sons Llp Room No. 207, {Formerly Known As M/S. K.P. Sanghvi & Sons} Gw-7011/7012, Mathru Mandir, Bharat Diamond Bourse, Mumbai – 400 007 Bandra Kurla Complex, Bandra (E), Mumbai – 400 051 Pan: Aaafk 8390 F (Appellant) (Respondent) Co No.237/Mum/2018 (A.Y: 2011-12) [Arising Out Of Ita No.2455/Mum/2017] M/S. K.P. Sanghvi & Sons Llp V. A.C.I.T Circle – 19(2) {Formerly Known As M/S. K.P. Sanghvi & Sons} Room No. 207, 2Nd Floor Gw-7011/7012, Mathru Mandir, Tardeo Bharat Diamond Bourse, Road, Mumbai – 400 007 Bandra Kurla Complex, Bandra (E), Mumbai – 400 051 Pan: Aaafk 8390 F (Appellant) (Respondent) Assessee By : Shri Aditya R. Ajgaonkar Department By : Shri Manoj Kumar Singh

For Appellant: Shri Aditya R. AjgaonkarFor Respondent: Shri Manoj Kumar Singh

Assessing Officer not doubted the genuineness of the sales and sales have been accepted. The Ld.CIT(A) followed various judicial pronouncements and estimated the profit element @5% from the purchases observing as under: - “7.10 In this case, I find that quantitative details were maintained, Ld. AO not doubted the genuineness ... assessee did produce cloth and sell finished goods, the entire amount covered under such purchase would not be subjected to tax and only the profit element embedded therein was to be 4 CO NO.237/MUM/2018 (A.Y: 2011-12) M/s. K.P. Sanghvi & Sons LLP taxed. While coming to the above conclusion

SMC Indu (Jv), Mumbai vs. Asst CIT 18(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 4454/MUM/2016[2009-10]Status: DisposedITAT Mumbai28 Sept 2018AY 2009-10

Bench: Shri C.N. Prasad, Hon'Ble & Shri N.K. Pradhan, Hon'Blem/S. Smc Indu (Jv) V. Acit – 18(2) 5Th Floor, Shop No. 9, Ground Kamana Chs Ltd., Building No. 1, Prabhadevi, Piramal Chambers, Mumbai – 400 028 Lalbaug, Mumbai – 400 012 Pan: Ablfs 6305 A (Appellant) (Respondent) Assessee By : Shri Neelkanth Khandelwal Department By : Shri Manoj Kumar Singh

For Appellant: Shri Neelkanth KhandelwalFor Respondent: Shri Manoj Kumar Singh
Section 271(1)Section 271(1)(c)

that penalty cannot be levied when an estimation is made. In this case an adhoc estimation was made by the Assessing Officer restricting the profit element in the 3 M/s. SMC INDU (JV) purchases to 25%. On identical situations the Coordinate Bench in the case of Shri Deepak Gogri ... have heard the rival submissions, perused the orders of the authorities below. In so far as the penalty levied on estimation of profit element on purchases is concerned, we are of the view that Assessing Officer had made only adhoc estimation of profit on certain purchases treated as unexplained expenditure

Kotak Mahindra Investments Ltd, Mumbai vs. DCIT RG 3(2), Mumbai

In the result, the appeal is partly allowed

ITA 5842/MUM/2013[2010-11]Status: DisposedITAT Mumbai28 Sept 2018AY 2010-11

Bench: Shri Sandeep Gosain () & Shri N.K. Pradhan () Assessment Year: 2010-11 Kotak Mahindra The Addl. Commissioner Of Investments Ltd. 27 Bkc, C- Vs. Income Tax Range 3(2) 27 G Block, Bandra Kurla Aayakar Bhavan Mumbai- Complex Bandra(E), 400020. Mumbai-400051. Pan No. Aaach1075K Appellant Respondent Assessee By : Mr. Farrokh Irani, Ar Revenue By : Mr. Manoj Kumar Singh, Dr Date Of Hearing : 29/08/2018 Date Of Pronouncement : 28/09/2018

For Appellant: Mr. Farrokh Irani, ARFor Respondent: Mr. Manoj Kumar Singh, DR
Section 143(3)Section 14A

Portfolio Management Schemes (PMS), the fee charged ranges between 2 and 2.5 per cent of the portfolio value which would be inclusive of a profit element for the portfolio manager. While the fixed administrative expenses were excluded on the ground that in the case of a large corporate taxpayer they

Starent Networks (India) Private Limited, Pune vs. Joint Commissioner of Income-Tax

In the result, appeal of assessee is partly allowed

ITA 585/PUN/2014[2009-10]Status: DisposedITAT Pune26 Sept 2018AY 2009-10

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.585/Pun/2014 यििाारण वषा / Assessment Year : 2009-10

For Appellant: Shri Rajendra AgiwalFor Respondent: Smt. Nirupama Kotru and Shri S.B. Prasad
Section 10ASection 143(3)Section 253(1)Section 92C(2)

DCIT (supra) has held that recovery of overhead charges being reimbursement of expenses is to be excluded being not commercial transaction involving profit element. We find merit in the plea of assessee and accordingly, direct the inclusion of ICRA Techno Analytics Ltd. in final set of comparables. 14. The second

Smt Madhu Chhanda Sirkar, Kolkata vs. CIT-Xvii, Kolkata

In the result ITA No.1704/Kol/2011 and ITA No

ITA 1084/KOL/2014[2007-2008]Status: DisposedITAT Kolkata26 Sept 2018AY 2007-2008

Bench: Hon’Ble Shri J.Sudhakar Reddy, Am & Smt. Madhumita Roy, Jm ] Assessment Year : 2007-08

For Appellant: Shri Soumitra Chowdhury, AdvocateFor Respondent: Shri G.Hangsing, CIT(DR)&

total income. The Gujarat High Court relied on some of its previous judgments to hold that "not the entire purchase price but only the profit element embedded in such purchases can be added to the income of the assessee." In the circumstances and particularly since the factual findings rendered ... Madhu Chhand Sirkar A.Y.2007-08 12 “5. Now comes the equally Important question as to whether the- entire discrepancy in stock addition or only the profit element embedded therein is to be considered for the impugned addition. We find this issue to be no more res integra as co-ordinate bench

Smt. Madhu Chhanda Sirkar, Kolkata vs. DCIT, Circle - 50, Kolkata

In the result ITA No.1704/Kol/2011 and ITA No

ITA 1704/KOL/2011[2007-08]Status: DisposedITAT Kolkata26 Sept 2018AY 2007-08

Bench: Hon’Ble Shri J.Sudhakar Reddy, Am & Smt. Madhumita Roy, Jm ] Assessment Year : 2007-08

For Appellant: Shri Soumitra Chowdhury, AdvocateFor Respondent: Shri G.Hangsing, CIT(DR)&

total income. The Gujarat High Court relied on some of its previous judgments to hold that "not the entire purchase price but only the profit element embedded in such purchases can be added to the income of the assessee." In the circumstances and particularly since the factual findings rendered ... Madhu Chhand Sirkar A.Y.2007-08 12 “5. Now comes the equally Important question as to whether the- entire discrepancy in stock addition or only the profit element embedded therein is to be considered for the impugned addition. We find this issue to be no more res integra as co-ordinate bench

DCIT, Circle - 50, Kolkata vs. Smt. Madhu Chanda Sirkar, Kolkata

In the result ITA No.1704/Kol/2011 and ITA No

ITA 1567/KOL/2011[2007-08]Status: DisposedITAT Kolkata26 Sept 2018AY 2007-08

Bench: Hon’Ble Shri J.Sudhakar Reddy, Am & Smt. Madhumita Roy, Jm ] Assessment Year : 2007-08

For Appellant: Shri Soumitra Chowdhury, AdvocateFor Respondent: Shri G.Hangsing, CIT(DR)&

total income. The Gujarat High Court relied on some of its previous judgments to hold that "not the entire purchase price but only the profit element embedded in such purchases can be added to the income of the assessee." In the circumstances and particularly since the factual findings rendered ... Madhu Chhand Sirkar A.Y.2007-08 12 “5. Now comes the equally Important question as to whether the- entire discrepancy in stock addition or only the profit element embedded therein is to be considered for the impugned addition. We find this issue to be no more res integra as co-ordinate bench

Dolsun Jewels, Mumbai vs. Assistant Commissioner of Income Tax - Circle 22(1), Mumbai

In the result, assessee’s appeal is partly allowed

ITA 930/MUM/2018[2007-08]Status: DisposedITAT Mumbai26 Sept 2018AY 2007-08

Bench: Shri Saktijit Dey

For Appellant: Shri Sashank DunduFor Respondent: Shri Swapan Kumar Bepari
Section 133(6)Section 143(3)Section 147

held that since the Assessing Officer himself has accepted that corresponding sales have been effected, the entire purchase cannot be added but the profit element embedded in such purchases can be considered for addition. Accordingly, he restricted the addition to 25% of the bogus purchases. 6. The learned Authorised Representative ... Therefore, only thing which is in doubt is the source of purchases. In these circumstances, the entire purchases cannot be disallowed but only the profit element embedded therein can be considered for addition. Therefore, to that extent, the learned Commissioner (Appeals) was justified in reversing the decision of the Assessing

Nikunj Yogesh Vora, Mumbai vs. Income Tax Officer 19(2)(4), Mumbai

In the result, appeal filed by the assessee is hereby ordered to be partly allowed

ITA 1852/MUM/2018[2011-12]Status: DisposedITAT Mumbai26 Sept 2018AY 2011-12

Bench: Shri B. R. Baskaran, Am & Shri Amarjit Singh, Jm

For Appellant: Shri Neelkanth KhandelwalFor Respondent: Shri N. Hemalatha (Sr. AR)
Section 143(1)Section 143(2)Section 147Section 148Section 234B

incremental gross profit @ 5.16% already shown by the Appellant, made by the AO to the income of the Appellant on account of possible profit element @ 12.5% embedded in purchases made through alleged non-genuine parties on the basis of information of the Sales Tax Department about suspicious dealers having rejected ... considerations, principles and evidences while he was overwhelmed, influenced and prejudiced by irrelevant considerations a factors. d) Without prejudice, the rate or percentage of profit element embedded in such purchases as fixed by the AO and confirmed by the CIT(A) is excessive and unreasonable on the facts

Pyaramid Industries, Mumbai vs. ACIT 25(3), Mumbai

In the result, appeal of the assessee is allowed

ITA 3269/MUM/2017[2009-10]Status: DisposedITAT Mumbai26 Sept 2018AY 2009-10

Bench: Shri G.S. Pannu & Shri Pawan Singhpyramid Industries Acit- 25(3) 245, 2Nd , Kumbarwada, Mumbai. 1St Floor, Room No.2, Near Gol Vs. Deval, Mumbai-400004. Pan: Aajfp1895P Appellant Respondent

For Appellant: Shri Anant M. Pai (AR)For Respondent: Shri Love Kumar (AR)
Section 144Section 253Section 254(1)Section 271Section 271(1)(c)Section 274

penalty is leviable on such estimated addition. It is settled law that addition made by Assessing Officer by resorting the estimation of profit element on alleged bogus purchase, no penalty is sustainable. Similar view was taken by Tribunal in case of Sushil Chhatrabuj Raheja (supra) (authored by same combination). Again

Girish Narapatchand Kanungo, Mumbai vs. ITO 19(1)(3), Mumbai

In the result, the appeal of the assessee in ITA no

ITA 1587/MUM/2017[2009-10]Status: DisposedITAT Mumbai26 Sept 2018AY 2009-10

Bench: Shri Mahavir Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.1587/Mum/2017 (नििाारण वर्ा / Assessment Year : 2009-10) बिाम/ Mr. Girish Narapatchand Ito 19(1)(3) Kanungo Matru Mandir, Prop. M/S. Tirupati Impex, Mumbai V. Flat No. 3, 2 Nd Floor, 5 Ramniwas Bldg, 2Nd Parsiwada Lane, Opp. V.P Road Police Station, Mumbai 400004 स्थायी ऱेखा सं./ Pan : Aoapk9201M (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) .. Assessee By: None Revenue By : Shri. C.S. Sharma सुनवाई की तारीख /Date Of Hearing : 19.09.2018 घोषणा की तारीख /Date Of Pronouncement : 26.09.2018 आदेश / O R D E R Per Ramit Kochar: This Appeal, Filed By Assessee, Being Ita No. 1587/Mum/2017, Is Directed Against Appellate Order Dated 22.12.2016 Passed By Learned Commissioner Of Income Tax (Appeals)-30, Mumbai (Hereinafter Called “The Cit(A)”), For Assessment Year 2009-10, The Appellate Proceedings Had Arisen Before Learned Cit(A) From Assessment Order Dated 10.03.2015 Passed By Learned Assessing Officer (Hereinafter Called “The Ao”) U/S 143(3) R.W.S. 147 Of The Income-Tax Act, 1961 (Hereinafter Called “The Act”) For Ay 2009-10. I.T.A. No.1587/Mum/2017

For Appellant: NoneFor Respondent: Shri. C.S. Sharma
Section 143(1)Section 143(3)Section 147Section 148

case and in law the learned Commissioner of Income Tax (Appeal)-30, Mumbai erred in confirming addition of Rs. 47,91,826/- on estimated profit element on treating the genuine purchases of Rs. 3,83,34,602/- as non-genuine purchases considering the purchases as bogus from the 11 parties ... during the course of re- assessment proceedings to make reasonable additions with respect to the alleged bogus purchases. The AO , thus , quantified the profit element in these alleged bogus purchases by bringing 12.5% of the alleged bogus purchases of Rs. 3,83,34,602/- as profit element embedded in these

Pushpak Auxichem P. Ltd, Thane vs. ITO WD 1(3), Kalyan

The appeal of the assessee is partly allowed

ITA 499/MUM/2018[2011-12]Status: DisposedITAT Mumbai25 Sept 2018AY 2011-12

Bench: Shri Joginder Singh & Shri Rajesh Kumarassessment Year: 2011-12 M/S Pushpak Auxichem Pvt. Income Tax Officer Ltd. Ward-1(3), बनाम/ 241/Business-2, Kasturi Mohan Plaza, 1St Floor, Vs. Plaza, 2Nd Floor, Manpada Wayle Nagar, Road, Dombivali (East), Khadak Pada, Thane-421201 Kalyan-421301 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No.Aabcp0099E

Section 148

sell the finished goods. In that view of the matter, as natural corollary, not the entire amount covered under such purchase, but the profit element embedded therein would be subject to tax. This was the view of this court in the case of Sanjay Oilcake Industries

Mumtaz Ali Nasruddin Kapoor, Mumbai vs. Income Tax Officer 27(2)(3), Mumbai

In the result, the appeal of the assessee is partly allowed

ITA 1171/MUM/2018[2009-10]Status: DisposedITAT Mumbai25 Sept 2018AY 2009-10

Bench: Shri C.N. Prasad & Shri Rajesh Kumarassessment Year: 2009-10

For Appellant: Shri Dinesh Shah, A.RFor Respondent: Shri Choudhary Arunkumar Singh, D.R
Section 133(6)Section 143(3)Section 148Section 148(2)Section 3

Tribunal have taken a consistent view that entire purchases can not be added to the income of the assessee and it is only the profit element embedded in the said alleged bogus purchases which has to be brought to tax. During the year the assessee has shown a gross profit

ITO 6(3)(2), Mumbai vs. Jaydeep Profiles P.Ltd, Mumbai

ITA 3236/MUM/2016[2009-10]Status: DisposedITAT Mumbai25 Sept 2018AY 2009-10

Bench: Shri Joginder Singh & Shri G. Manjunathaassessment Year: 2009-10 Income Tax Officer 6(3)(2), Jaydeep Profiles P. Ltd., R No.503, 5Th Floor, Aayakar 142/7 Lakdi Bunder Road, बनाम/ Bhavan, M.K.Road, Darukhana, Reay Road, Vs. Mumbai 400 020 Mumbai 400 086 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. Aaacj8998B Assessment Year: 2009-10 Jaydeep Profiles P. Ltd., Income Tax Officer 6(3)(2), 142/7 Lakdi Bunder Road, R No.503, 5Th Floor, Aayakar बनाम/ Darukhana, Reay Road, Bhavan, M.K.Road, Vs. Mumbai 400 086 Mumbai 400 020 ("नधा"रती /Assessee) (राज"व /Revenue) P.A. No. Aaacj8998B 2 & 2698/Mum/2016

Section 133(6)Section 139Section 142Section 143Section 147Section 148

sell the finished goods. In that view of the matter, as natural corollary, not the entire amount covered under such purchase, but the profit element embedded therein would be subject to tax. This was the view of this court in the case of Sanjay Oilcake Industries

Jaydeep Profiles Pvt. Ltd., Mumbai vs. ITO WD 6 (3)(2), Mumbai

ITA 2698/MUM/2016[2009-10]Status: DisposedITAT Mumbai25 Sept 2018AY 2009-10

Bench: Shri Joginder Singh & Shri G. Manjunathaassessment Year: 2009-10 Income Tax Officer 6(3)(2), Jaydeep Profiles P. Ltd., R No.503, 5Th Floor, Aayakar 142/7 Lakdi Bunder Road, बनाम/ Bhavan, M.K.Road, Darukhana, Reay Road, Vs. Mumbai 400 020 Mumbai 400 086 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. Aaacj8998B Assessment Year: 2009-10 Jaydeep Profiles P. Ltd., Income Tax Officer 6(3)(2), 142/7 Lakdi Bunder Road, R No.503, 5Th Floor, Aayakar बनाम/ Darukhana, Reay Road, Bhavan, M.K.Road, Vs. Mumbai 400 086 Mumbai 400 020 ("नधा"रती /Assessee) (राज"व /Revenue) P.A. No. Aaacj8998B 2 & 2698/Mum/2016

Section 133(6)Section 139Section 142Section 143Section 147Section 148

sell the finished goods. In that view of the matter, as natural corollary, not the entire amount covered under such purchase, but the profit element embedded therein would be subject to tax. This was the view of this court in the case of Sanjay Oilcake Industries