In the result, both the appeals of revenue and that of assessee are dismissed
Bench: Shri Mahavir Singh, Jm & Shri M. Balaganesh, Am]
penalty proceedings u/s. 271(1)(c) has been initiated separately. Since these purchases are not accounted in the books of accounts or these transactions are outside the regular books of accounts were sale this purchases as well in which it will be earning gross profit. The GP rate of the assessee company that arbitrary is 13.39%. Hence, the same that