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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

Gd Foods Manufacturing (India) Pvt. Ltd., New Delhi vs. ACIT, Central Circle- 26, New Delhi

The appeal of the revenue is dismissed

ITA 1180/DEL/2018[2014-15]Status: DisposedITAT Delhi06 Sept 2018AY 2014-15

Bench: Shri Prashant Maharishi & Shri K. N. Chary

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Sanjit Singh, CIT DR
Section 132Section 153A

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ―C‖: NEW DELHI BEFORE SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER AND SHRI K. N. CHARY

Shri Dilip Kumar Nayak, Bhubaneswar vs. JCIT, Range-2, Bhubaneswar

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

ITA 86/CTK/2017[2010-11]Status: DisposedITAT Cuttack05 Sept 2018AY 2010-11

Bench: S/Shri N.S Saini & Pavan Kumar Gadaleassessment Year : 2010-2011

For Appellant: Sri P.K.Mishra, ARFor Respondent: Shri A.K.Mohapatra, CIT DR

International Inc. in ITA Nos.1073/Hyd/2004, 1074/Hyd/2004, 720/Hyd/2005 and 721/Hyd/2005 dated 30.6.2010. The Hon’ble ITAT in the cited decision held that there is no profit element in the reimbursement of expenses, hence the reimbursement of expenditure received by the recipient does

ACIT - 26(1), Mumbai vs. Farhana Nisar Siddiqui, Mumbai

Appeal stand dismissed

ITA 2831/MUM/2017[2011-12]Status: DisposedITAT Mumbai05 Sept 2018AY 2011-12

Bench: Shri Saktijit Dey, Jm & Shri Manoj Kumar Aggarwal, Am

For Appellant: NoneFor Respondent: Rajiv K. Gubangotra, Ld. DR
Section 144Section 147

disputed by the revenue and there could be no sale without purchase of material. Therefore, the profits were rightly estimated @12.5% to account for profit element embedded in the alleged bogus purchases transactions carried out by the assessee. Therefore, the stand of Ld. CIT(A), in this regard

DCIT, Ludhiana vs. M/S Palace Jewellers Pvt. Ltd., Ludhiana

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

ITA 247/CHANDI/2017[2013-14]Status: DisposedITAT Chandigarh04 Sept 2018AY 2013-14

Bench: Ms. Diva Singh & Ms. Annapurna Gupta

For Appellant: Shri Ashish Abrol, CIT-DRFor Respondent: Shri Tej Mohan Singh, Advocate
Section 132

gross profit margin of the assessee company was 2.76 % for the ending 30.10.2012. If this rate of gross profit is applied, the profit element comes to Rs. 17,43,480/- on the amount of unaccounted sales, -which stands covered by the amount of additional income of Rs. 4 Crores already ... such sales and investment made to effect such unaccounted sales of Rs.6,31,69,524/- is also required to be made. As far as profit element is concerned, it is seen that assessee has shown G.P. of 2.76% on the sales made between the period 01.04.2012 to 31.10.2012 i.e. upto

Palace Jewellers Pvt. Ltd., Ludhiana vs. DCIT, Ludhiana

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

ITA 187/CHANDI/2017[2013-14]Status: DisposedITAT Chandigarh04 Sept 2018AY 2013-14

Bench: Ms. Diva Singh & Ms. Annapurna Gupta

For Appellant: Shri Ashish Abrol, CIT-DRFor Respondent: Shri Tej Mohan Singh, Advocate
Section 132

gross profit margin of the assessee company was 2.76 % for the ending 30.10.2012. If this rate of gross profit is applied, the profit element comes to Rs. 17,43,480/- on the amount of unaccounted sales, -which stands covered by the amount of additional income of Rs. 4 Crores already ... such sales and investment made to effect such unaccounted sales of Rs.6,31,69,524/- is also required to be made. As far as profit element is concerned, it is seen that assessee has shown G.P. of 2.76% on the sales made between the period 01.04.2012 to 31.10.2012 i.e. upto

Ajay Trivedi, Mumbai vs. Income Tax Officer 2(1), Thane

In the result, both the appeals filed by the assessee for assessment years

ITA 354/MUM/2018[2009-10]Status: DisposedITAT Mumbai04 Sept 2018AY 2009-10

Bench: Shri R.C. Sharma (Am) & Shri Ram Lal Negi (Jm) Assessment Year: 2009-2010 & Assessment Year: 2010-2011 Shri Ajay Trivedi, The Ito-2(1), B-106, Ridhi Sidhi Apartment, Room No. 9, A-Wing, 6Th Floor, Navghar Road, Ashar I-T Park, Bhatander (East)- 401105 Vs. Wagle Industrial Estate, Thane (W)- 400604 Pan: Acppt0186P (Appellant) (Respondent)

For Appellant: Shri Surji D. Chheda (AR)For Respondent: Ms. N. Hemalatha (DR)
Section 133(6)Section 139Section 143Section 143(1)Section 143(2)Section 147Section 148

Assessment Year: 2009-2010 and 2010-11 Court in the case of Simit P. Sheth (supra), in which it has been held that only profit element embedded in such purchases can be added to income of the assessee. In our considered view, the cases relied upon by the Ld. counsel

Arvindkumar G. Shah, Mumbai vs. Income Tax Officer, Ward 19(1)(1), Mumbai

In the result, appeal filed by the assessee for assessment year

ITA 1779/MUM/2018[2009-10]Status: DisposedITAT Mumbai04 Sept 2018AY 2009-10

Bench: Shri R.C. Sharma (Am) & Shri Ram Lal Negi (Jm) Assessment Year: 2009-10 Shri Arvind Kumar G Shah, The Income Tax Officer 19(1)(1), 59, 1St Floor, Khetwadi Lane, Matru Mandir, Nana Chowk, Mumbai - 400004 Mumbai - 400007 Vs. Pan: Ancps4341P (Appellant) (Respondent) Assessee By : Shri Arvind Kumar G Shah (Ar) Revenue By : Ms. N. Hemalatha (Dr) Date Of Hearing: 11/06/2018 Date Of Pronouncement: 04/09/2018

For Appellant: Shri Arvind Kumar G Shah (AR)For Respondent: Ms. N. Hemalatha (DR)
Section 143Section 143(3)Section 147Section 148Section 234A

gross reasonable Gross Profit.” 3. Accordingly, AO made addition of 12.5% of the total amount of the bogus purchases taking into consideration the profit element involved in the questioned purchases, passed the assessment order u/s 143(3) read with section 147 of the Act and determined the total income

Ghosh Bishayee & Associates, Burdwan vs. ACIT, Circle-1, Burdwan

Appeal is partly allowed

ITA 1550/KOL/2016[2011-12]Status: DisposedITAT Kolkata31 Aug 2018AY 2011-12

Bench: Shri S.S.Godara & Dr. A.L. Sainiassessment Year :2011-12

Section 143(3)

impugned addition in principle. 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 ... this tribunal in M/s Subarna Rice Mill vs. ITO ITA No.1781/Kol/2014 decided on 30.06.2015 holding only the profit element liability to be added in such circumstances; stand upheld by hon'ble jurisdictional high court’s recent judgment dated 20.06.2018 in ITAT 196 of 2015 GA No.4047 of 2015. We therefore

Core Energy Systems P.Ltd, Dombivali vs. Asst CIT Cir 1, Kalyan

In the result the appeal is partly allowed

ITA 1722/MUM/2017[2011-12]Status: DisposedITAT Mumbai31 Aug 2018AY 2011-12

Bench: Shri Mahavir Singh () & Shri N.K. Pradhan () Assessment Year: 2011-12 M/S. Core Energy Systems Acit-Circle -1, Kalyan. Private Limited, Vs. Plot-X-16, Prathamesh Vyapari Sankul, Behind Kamat Hospital, Midc, Dombivli-421 203. Pan No. Aaccc 4753 F Appellant Respondent Assessee By : Mr. Krunal Tate, Ar Revenue By : Mr. Abi Rama Kartikeyan, Dr Date Of Hearing : 21 /08/2018 Date Of Pronouncement: 31/08/2018

For Appellant: Mr. Krunal Tate, ARFor Respondent: Mr. Abi Rama Kartikeyan, DR
Section 131(1)Section 133(6)Section 143(3)

purchases were not bogus but were made from parties other than those mentioned in the books of account, not entire purchase price but only profit element embedded in such purchases can be added to income of the assessee. The Hon’ble High Court referred to a similar view taken

Asst CIT 15(2)(1), Mumbai vs. Haware Construction P. Ltd, Navi Mumbai

Appeal is partly allowed

ITA 3321/MUM/2016[2009-10]Status: DisposedITAT Mumbai31 Aug 2018AY 2009-10

Bench: Shri Mahavir Singh () & Shri N.K. Pradhan ()

For Appellant: Mr. J.P.Bairagra, ARFor Respondent: Mr. Somnath M. Wajale
Section 143(3)Section 147Section 148

that the ld. CIT(A) erred in estimating the profit to the extent of 12.5% of the purchases of Rs.2,20,472/-, considering the profit element embedded in ITA No. 3321/MUM/2016 & ITA No.3172/Mum/2016 M/s. Haware Construction Pvt.Ltd. such purchases without giving any finding as to how the above estimate ... purchases were not bogus but were made from parties other than those mentioned in the books of account, not entire purchase price but only profit element embedded in such purchases can be added to income of the assessee. The Hon’ble High Court referred to a similar view taken

Hiraram Jodharam Chaudhary, Mumbai vs. Income Tax Officer 19(1)(5), Mumbai

In the result, appeal of the assessee is dismissed

ITA 1165/MUM/2018[2009-10]Status: DisposedITAT Mumbai30 Aug 2018AY 2009-10

Bench: Shri Joginder Singh & Shri Rajesh Kumarassessment Year: 2009-10

For Appellant: NoneFor Respondent: Shri Bepari, D.R
Section 133(6)Section 143(1)Section 143(3)Section 147Section 69C

fairly sustained the addition to the tune of 6.8% of the total bogus purchases in order to tax the profit element. Accordingly, we are inclined to the order of Ld. CIT(A). 8. In the result, appeal of the assessee is dismissed. Order pronounced in the open court

Dinesh R. Shah, Mumbai vs. Income Tax Officer, Ward 19(3)(2), Mumbai

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

ITA 1876/MUM/2018[2009-10]Status: DisposedITAT Mumbai29 Aug 2018AY 2009-10

Bench: Shri R. C. Sharma, Am & Shri Amarjit Singh, Jm आयकर अपील सं/ I.T.A. No.1876/Mum/2018 (निर्धारण वर्ा / Assessment Year: 2009-10) Shri Dinesh R. Shah (Legal बिधम/ Ito Ward-19(3)(2), Matru Heir Of Late Shri Mandir, Nana Chowk Vs. Rugnathmal A. Shah), 29, Mumbai-400007. Trimbak, Parshuram Street, 5Th Kumbharwada, Mumbai- 400004. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aktps4623G (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Revenue By: Ms. N. Hemlatha (Dr) Assessee By: None सुनवाई की तारीख / Date Of Hearing: 09.07.2018 घोषणा की तारीख /Date Of Pronouncement: 29.08.2018 आदेश / O R D E R Per Amarjit Singh, Jm: The Assessee Has Filed The Present Appeal Against The Order Dated 02.01.2018 Passed By The Commissioner Of Income Tax (Appeals) - 30, Mumbai [Hereinafter Referred To As The “Cit(A)”] Relevant To The A.Y.2009-10. 2. The Assessee Has Raised The Following Grounds: - “1. On The Facts & In The Circumstances Of The Case & In Law The Learned Commissioner Of Income Tax (Appeal) Erred In

For Appellant: NoneFor Respondent: Ms. N. Hemlatha (DR)
Section 133(6)Section 142(1)Section 143Section 143(1)Section 143(3)Section 147Section 148Section 14SSection 234A

Appeal) erred in ITA.NO.1876/M/2018 A.Y. 2009-10 (a) confirming addition of Rs 3518OO/- to the total income of the appellant by estimating profit element @ 6 5% on alleged bogus purchases of Rs.5412307/-. (b) estimating rate of profit at 6.5% on alleged bogus purchases over and above gross profit declared ... assessee* Thus, the Issue would boil down whether the element of profit adopted by the AO @12,5% treating the same as the profit element embedded in such bogus purchases, which the appellant would have made from some unknown entities is correct or not. 7.7 Hon'ble Gujarat High Court

Asst CIT 27(2), Navi Mumbai vs. N.R Cororation, Mumbai

In the result, the appeal of the revenue is hereby dismissed

ITA 1712/MUM/2017[2008-09]Status: DisposedITAT Mumbai29 Aug 2018AY 2008-09

Bench: Shri R. C. Sharma, Am & Shri Amarjit Singh, Jm आयकर अपील सं/ I.T.A. No.1712/Mum/2017 (निर्धारण वर्ा / Assessment Year: 2008-09) The Acit-27(2), Room No. बिधम/ M/S. N.R. Corporation Shop 420, 4Th Floor, Tower No. 6, No. 13, Navrathna Building, Vs. Vashi Railway Station New Maneklal Estate, Lbs Complex, Vashi, Navi Marg, Ghatkopar West, Mumbai-400703. Mumbai-400086. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aacfn8943N (अपीलाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: NoneFor Respondent: Shri T. A Khan
Section 133(6)Section 142(1)Section 143(2)Section 148Section 68

Howsoever, vital question while considering whether the entire amount of purchases should be added back to the income of the assessee or only the profit element embedded therein was to ascertain whether the purchases themselves were completely bogus and non existent or that the purchases were actually made ... made from the parties other than those mentioned in the books of accounts. That being the position, not the entire purchase price but only profit element embedded in such purchases can be added to the income of the assessee. So much is dear by decision of this Court. In particular

Linfox Logistics (India) P.Ltd, Mumbai vs. DCIT 10(1), Mumbai

In the result, all the appeals filed by the assessee are hereby allowed

ITA 3948/MUM/2016[2010-11]Status: DisposedITAT Mumbai29 Aug 2018AY 2010-11

Bench: Shri G. S. Pannu, Am & Shri Amarjit Singh, Jm

For Appellant: Shri Rajan Vora (AR)For Respondent: Shri Rajesh Kumar Yadav (DR)
Section 195Section 250Section 28Section 36Section 37Section 40

Representative of the assessee has argued that the said payment was purely reimbursement in nature and in absence of any profit element or mark-up, the assessee was not liable to deduct the TDS ,therefore, the expenses of Rs.5,92,643/- on account of reimbursement towards consultancy and professional fees ... professional fees and service apartment charges are ITA. No. 3948/M/2016 3949/M/2016 A.Y. 2010-11 2011-12 reimbursed by the Appellant at actual, without any profit element or mark-up and were not liable to deduction of tax at source. 5 Disallowance of expense of Rs.68,47,379 on account

Skylark Build, Mumbai vs. Asst CIT Cen Cir 4(2), Mumbai

ITA 4370/MUM/2015[2007-08]Status: DisposedITAT Mumbai29 Aug 2018AY 2007-08

Bench: Shri Joginder Singh & Shri Rajesh Kumarassessment Year: 2007-08 M/S. Skylark Build Acit, Central Circle-4(2) 402, Sagar Avenue 4Th Floor, Aayakar Bhavan बनाम/ Plot B-54, Junction Of M.K.Road, Vs. Lallubhai Park & S.V. Road Mumbai 400020 Andheri (W), Mumbai 400058 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aazfs0404K Assessment Year: 2008-09 M/S. Skylark Build Acit, Central Circle-4(2) 402, Sagar Avenue 4Th Floor, Aayakar Bhavan बनाम/ Plot B-54, Junction Of M.K.Road, Vs. Lallubhai Park & S.V. Road Mumbai 400020 Andheri (W), Mumbai 400058 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aazfs0404K

आयकर अपील"य अ"धकरण, मुंबई "यायपीठ, “एच” मुंबई। IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES “H”, MUMBAI "ी जो

Skylark Build, Mumbai vs. Asst CIT Cen Cir 4(2), Mumbai

ITA 3237/MUM/2015[2008-09]Status: DisposedITAT Mumbai29 Aug 2018AY 2008-09

Bench: Shri Joginder Singh & Shri Rajesh Kumarassessment Year: 2007-08 M/S. Skylark Build Acit, Central Circle-4(2) 402, Sagar Avenue 4Th Floor, Aayakar Bhavan बनाम/ Plot B-54, Junction Of M.K.Road, Vs. Lallubhai Park & S.V. Road Mumbai 400020 Andheri (W), Mumbai 400058 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aazfs0404K Assessment Year: 2008-09 M/S. Skylark Build Acit, Central Circle-4(2) 402, Sagar Avenue 4Th Floor, Aayakar Bhavan बनाम/ Plot B-54, Junction Of M.K.Road, Vs. Lallubhai Park & S.V. Road Mumbai 400020 Andheri (W), Mumbai 400058 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aazfs0404K

आयकर अपील"य अ"धकरण, मुंबई "यायपीठ, “एच” मुंबई। IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES “H”, MUMBAI "ी जो

DCIT Cen Cir 4(2), Mumbai vs. Sudhakar M. Shetty, Mumbai

ITA 2906/MUM/2015[2011-12]Status: DisposedITAT Mumbai29 Aug 2018AY 2011-12

Bench: Shri Joginder Singh & Shri Rajesh Kumarassessment Year: 2007-08 M/S. Skylark Build Acit, Central Circle-4(2) 402, Sagar Avenue 4Th Floor, Aayakar Bhavan बनाम/ Plot B-54, Junction Of M.K.Road, Vs. Lallubhai Park & S.V. Road Mumbai 400020 Andheri (W), Mumbai 400058 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aazfs0404K Assessment Year: 2008-09 M/S. Skylark Build Acit, Central Circle-4(2) 402, Sagar Avenue 4Th Floor, Aayakar Bhavan बनाम/ Plot B-54, Junction Of M.K.Road, Vs. Lallubhai Park & S.V. Road Mumbai 400020 Andheri (W), Mumbai 400058 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aazfs0404K

आयकर अपील"य अ"धकरण, मुंबई "यायपीठ, “एच” मुंबई। IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES “H”, MUMBAI "ी जो

Hanjin Shipping Company Ltd, Mumbai vs. DCIT (It) RG 2(2)(2), Mumbai

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

ITA 1538/MUM/2017[2013-14]Status: DisposedITAT Mumbai28 Aug 2018AY 2013-14

Bench: Shri Saktijit Dey & Shri Ramit Kochar

For Appellant: NoneFor Respondent: Ms. Sunita Billa, DR
Section 143(3)Section 144C(5)Section 44B

Mitchell Drilling International Pvt. Ltd.” (supra), we hold that service tax collected by the assessee and paid to the government account having no profit element, cannot be included in the gross receipts for computation of income under section 44B of the Act. This issue is accordingly decided in favour ... allow the appeal of the assessee by holding that the service tax collected by the assessee and paid to the government account having no profit element , cannot be included in the gross receipts from operation of ships for computation of income u/s 44B of the 1961 Act . Merely because

ITO 30(2)(2), Mumbai vs. Laxmikant Sharma, Mumbai

In the result, cross objection of the assessee is partly allowed

ITA 4102/MUM/2017[2009-10]Status: DisposedITAT Mumbai27 Aug 2018AY 2009-10

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

For Appellant: Shri A.K. Sharma, A.RFor Respondent: Shri Satishchandra Rajore, D.R
Section 194CSection 194ISection 40

third party who has incurred expenses on behalf of the assessee. It is a settled law that any reimbursement of expenses involving no profit element is not liable for TDS and therefore we are not in agreement with the conclusion of the Ld. CIT(A) on this issue

ACIT Cir 11(3)(1), Mumbai vs. Total Tools and Equipments P.Ltd, Mumbai

In the result, the appeal of Revenue is dismissed

ITA 2127/MUM/2017[2010-11]Status: DisposedITAT Mumbai24 Aug 2018AY 2010-11

Bench: Sri Mahavir Singh, Jm & Sri G Manjunatha, Am Aayakr Apila Sam./ Ita No. 2127/Mum/2017 (Inaqa-Arna Baya- / Assessment Year 2010-11) The Asst. Commissioner Of Total Tools & Equipments Income Tax, Circle-11(3)(1), Pvt. Ltd. Room No. 427, Aayakar A-57, 1St Floor, Giriraj Indl. Vs. Bhavan, 4Th Floor, M.K. Marg, Estate, Mahakali Caves Rd, Mumbai-400 020 Andheri (E), Mumbai-400 093 .. (Apilaaqai- / Appellant) (P`%Yaqaai- / Respondent) स्थायी लेखा िं./Pan No. Aaact4144P

For Appellant: Shri DG Pansari, DRFor Respondent: Shri Ajay R. Singh, AR
Section 133(6)Section 143(3)

laws cited (supra), I estimate the suppressed profit to the extent of 12.5% of the purchases made from the bogus entities, as the suppressed profit element embedded in such purchases. This estimation is in addition to the GP 5 shown by the appellant. Accordingly, this ground of appeal is partly