M/S. MUKKA PROTEINS LIMITED (FORMERLY KNOW AS MUKKA SEA FOOD INDUSTRIES LTD., ),MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, MANGALORE

bogus purchases accounted by the assessee as\nfound by any of the lower authorities.”\n3.7 In the instant case though assessee had received the supplies\nfrom the persons in respect to whom additional income is offered, it\nhas admitted additional income to co-operate with the department.\nOnly where the parties have confirmed, the additional income is not\noffered

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD) CENTRAL CIRCLE-1(3), BENGALURU

In the result, the appeals of the assessee for Assessment Years

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

100 taxmann.com 266 (Karnataka-HC) has held that where the result of an addition is an abnormally high GP rate, the same cannot be sustained. . ITA No.399-410/Bang/2025 Page 17 of 33 5.6 The AR also argued that the AO adopted arbitrary percentages of disallowance—sometimes 25% and at other times 20%—without any basis. If 75% of the cash purchases

BYSANI ADINARAYAGUPTHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, the appeals of the assessee for Assessment Years

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

100 taxmann.com 266 (Karnataka-HC) has held that where the result of an addition is an abnormally high GP rate, the same cannot be sustained. . ITA No.399-410/Bang/2025 Page 17 of 33 5.6 The AR also argued that the AO adopted arbitrary percentages of disallowance—sometimes 25% and at other times 20%—without any basis. If 75% of the cash purchases

BYSANI ADINARAYAGUPATHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

100 taxmann.com 266 (Karnataka-HC) has held\nthat where the result of an addition is an abnormally high GP rate, the\nsame cannot be sustained.\n5.6 The AR also argued that the AO adopted arbitrary percentages of\ndisallowance—sometimes 25% and at other times 20%—without any\nbasis. If 75% of the cash purchases are accepted as genuine, there

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

100 taxmann.com 266 (Karnataka-HC) has held\nthat where the result of an addition is an abnormally high GP rate, the\nsame cannot be sustained.\n5.6 The AR also argued that the AO adopted arbitrary percentages of\ndisallowance—sometimes 25% and at other times 20%—without any\nbasis. If 75% of the cash purchases are accepted as genuine, there

DCIT, GULBARGA vs. M/S JUPITERBIOSCIENCE LTD.,, BIDAR

In the result, appeal by the revenue is partly allowed

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaran

100% allowance under Section 35(2)(ia) of the Act for having purchased the machineries to its R & D Department. The learned counsel for the Revenue has rightly placed reliance upon the unreported judgment referred to supra in support of his legal submissions that the claim of the assessee for having acquired machineries which is a movable property runs about

DCIT, GULBARGA vs. M/S JUPITER BIOSCIENCE LTD.,, BIDAR

In the result, appeal by the revenue is partly allowed

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaran

100% allowance under Section 35(2)(ia) of the Act for having purchased the machineries to its R & D Department. The learned counsel for the Revenue has rightly placed reliance upon the unreported judgment referred to supra in support of his legal submissions that the claim of the assessee for having acquired machineries which is a movable property runs about

ACIT, GULBARGA vs. M/S. JUPITER BIOSCIENCE LTD.,, BIDAR

In the result, appeal by the revenue is partly allowed

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaran

100% allowance under Section 35(2)(ia) of the Act for having purchased the machineries to its R & D Department. The learned counsel for the Revenue has rightly placed reliance upon the unreported judgment referred to supra in support of his legal submissions that the claim of the assessee for having acquired machineries which is a movable property runs about

DCIT, GULBARGA vs. M/S JUPITERBIOSCIENCE LTD.,, BIDAR

In the result, appeal by the revenue is partly allowed

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaran

100% allowance under Section 35(2)(ia) of the Act for having purchased the machineries to its R & D Department. The learned counsel for the Revenue has rightly placed reliance upon the unreported judgment referred to supra in support of his legal submissions that the claim of the assessee for having acquired machineries which is a movable property runs about

DCIT, GULBARGA vs. M/S JUPITER BIOSCIENCE LTD.,, BIDAR

In the result, appeal by the revenue is partly allowed

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaran

100% allowance under Section 35(2)(ia) of the Act for having purchased the machineries to its R & D Department. The learned counsel for the Revenue has rightly placed reliance upon the unreported judgment referred to supra in support of his legal submissions that the claim of the assessee for having acquired machineries which is a movable property runs about

DCIT, GULBARGA vs. M/S JUPITER BIOSCIENCE LTD.,, BIDAR

In the result, appeal by the revenue is partly allowed

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaran

100% allowance under Section 35(2)(ia) of the Act for having purchased the machineries to its R & D Department. The learned counsel for the Revenue has rightly placed reliance upon the unreported judgment referred to supra in support of his legal submissions that the claim of the assessee for having acquired machineries which is a movable property runs about

BYSANI ADINARAYAGUPTHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRCLE 1(3), BENGALURU

In the result, all the appeals of the assessee for A

100 taxmann.com 266 (Karnataka-HC) has held\nthat where the result of an addition is an abnormally high GP rate, the\nsame cannot be sustained.\n\n5.6 The AR also argued that the AO adopted arbitrary percentages of\ndisallowance—sometimes 25% and at other times 20%—without any\nbasis. If 75% of the cash purchases are accepted as genuine, there

BYSANI ADINARAYAGUPTHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

100 taxmann.com 266 (Karnataka-HC) has held\nthat where the result of an addition is an abnormally high GP rate, the\nsame cannot be sustained.\n5.6 The AR also argued that the AO adopted arbitrary percentages of\ndisallowance—sometimes 25% and at other times 20%—without any\nbasis. If 75% of the cash purchases are accepted as genuine, there

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

100 taxmann.com 266 (Karnataka-HC) has held\nthat where the result of an addition is an abnormally high GP rate, the\nsame cannot be sustained.\n5.6 The AR also argued that the AO adopted arbitrary percentages of\ndisallowance—sometimes 25% and at other times 20%—without any\nbasis. If 75% of the cash purchases are accepted as genuine, there

BYSANI ADINARAYAGUPTHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

100 taxmann.com 266 (Karnataka-HC) has held\nthat where the result of an addition is an abnormally high GP rate, the\nsame cannot be sustained.\n\n5.6 The AR also argued that the AO adopted arbitrary percentages of\ndisallowance—sometimes 25% and at other times 20%—without any\nbasis. If 75% of the cash purchases are accepted as genuine, there

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX, (OSD) CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

100 taxmann.com 266 (Karnataka-HC) has held\nthat where the result of an addition is an abnormally high GP rate, the\nsame cannot be sustained.\n\n5.6 The AR also argued that the AO adopted arbitrary percentages of\ndisallowance—sometimes 25% and at other times 20%—without any\nbasis. If 75% of the cash purchases are accepted as genuine, there

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD) CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

100 taxmann.com 266 (Karnataka-HC) has held\nthat where the result of an addition is an abnormally high GP rate, the\nsame cannot be sustained.\n\n5.6 The AR also argued that the AO adopted arbitrary percentages of\ndisallowance—sometimes 25% and at other times 20%—without any\nbasis. If 75% of the cash purchases are accepted as genuine, there

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

100 taxmann.com 266 (Karnataka-HC) has held\nthat where the result of an addition is an abnormally high GP rate, the\nsame cannot be sustained.\nPage 17 of 33\nITA No.399-410/Bang/2025\n5.6 The AR also argued that the AO adopted arbitrary percentages of\ndisallowance—sometimes 25% and at other times 20%—without any\nbasis. If 75% of the cash purchases