also test checked. The A.O. also confronted the assessee on
low GP rate and the reason for the same was also furnished ... toto. The
A.O. observed that reasons for low GP rate submitted by the assessee
are general in nature and cannot be considered
concerns of the assessed group, suppressing the sales and by showing low GP rate. After examining all the documents seized during the course of search ... officer, the assessing officer drew an inference that assessed has shown low GP rate while filing the regular returns. At annex. AA-19 seized from
GP rate
by the Assessing Officer. The ld. DR submitted that the Assessing Officer
rightly noted that during the year under consideration, GP rate ... Year: 2006-07
Officer to add difference on the basis of low GP rate compared with earlier
Asstt. Years.
7. On careful consideration
Additions Amount [Rs.]
1995-96 (i)On account of low GP rate (ii) U/s 68 8,55,638
NIL
Total ... 3282/Ahd/2009
1996-97 (i)On account of low GP rate
cent. Thus, the AO rejected the assessee's GP rate of 0.18 per cent and estimated GP at 0.41 per cent and trading addition ... justified in rejecting the book results on the plea of low GP rate and absence of particulars of address of the customers, without which verification
Deleting the trading addition made by the AO on account of low GP rate by invoking provision of Section 145 of IT Act.
2. Directing ... asst. yrs. 2004-05 and 2005-06 respectively, on account of low GP rate by invoking Section 145 of IT Act.
3. Briefly the facts
account of suppression of yield and low GP and deletion of disallowance of Rs. 60,000 out of advertisement and publicity expenses for the assessment ... justified in rejecting the book results merely on account of low yield, low GP rate, etc. Accepting the contentions of the assessee, the Commissioner (Appeals
justification for the impugned addition. As regards the alleged low GP rate, he drew our attention to the details in assessee's submissions ... alleged low GP and, secondly, excess wages claimed by the assessee. As regards the addition on account of alleged low GP it is noted that
rate contract and the assessee could not increase selling rate. The assessee stated that this resulted in lowering GP rate. In regard to business promotion ... assessee has stated that the explanation given by the assessee regarding low GP rate does not explain the fall of GP rate by a massive
finally made by estimating higher sales and by adopting higher GP rate, the Tribunal held that this did not establish a charge of concealment ... plausible explanation in respect of purchases and sales as well as low GP rate. This explanation was, however, treated as insufficient by the Revenue authorities
