Dy. CIT v. DSG Papers (P.) Ltd. (2025) 127 ITR 410 (Chd.)(Trib.)

S. 143(3): Assessment-Gross profit-Ad hoc enhancement without defects in books-Addition deleted-Depreciation-CPC disallowance without reasons-Matter remanded-[S.32, 143(1), 145(3)]

The Assessing Officer applied a gross profit rate of 25 per cent. and the Commissioner (Appeals) reduced it to 24 per cent. The Tribunal found both estimates arbitrary since the books were fully vouched and no defects were established. The addition sustained by the Commissioner (Appeals) was deleted. The Tribunal held that the Centralised Processing Centre had disallowed depreciation on the assessee’s power plant without assigning any reason. As no incriminating material had been found during the search, the issue was restored to the Assessing Officer for fresh adjudication on merits.  (AY. 2014-15 to 2020-21).

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