Sohan Lal Aggarwal v. ACIT (2021) 190 ITD 850 (Delhi)(Trib.)

S. 145 : Method of accounting-Sale proceeds-Difference between books of account and as per TDS certificate-Only embedded portion of profits was to be taken into-addition cannot be made of entire turnover. [S. 69A]

Held that where there was difference between assessee’s books of account and accounts as per TDS certificate, then on said difference, only embedded portion of profits was to be taken into consideration and addition was to be made thereon. Total sale does not represent profit of assessee and only net profit rate has to be adopted and once net profit is adopted. there was no justification in making addition of entire turnover to income of assessee  (AY. 2013-14)