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Income Tax

Arbitrary 3% Profit Estimation Struck Down by ITAT Hyderabad

Case Law Details

TaxGuru Citation
2025 taxguru.in 12695
Case Name
Yugendra Puppala Vs ACIT (ITAT Hyderabad)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2015-16
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Yugendra Puppala Vs ACIT (ITAT Hyderabad)

AO can’t pluck 3% profit from thin air: ITAT upholds limited scrutiny scope but remands arbitrary estimation

ITAT Hyderabad   partly allowed assessee’s appeal. Tribunal rejected legal challenge to assessment on ground of alleged illegal expansion of limited scrutiny, holding that where one of the CASS parameters was sales turnover mismatch, AO was justified in examining purchases as a necessary corollary &  no separate approval for conversion into complete scrutiny was required.

However, on merits, ITAT found that estimation of net profit at 3% of gross receipts was wholly arbitrary, as AO had neither relied on industry data nor past profit history of Assessee, nor recorded any rational basis. Tribunal held that profit estimation cannot be ad-hoc &  directed AO to recompute net profit by adopting either industry average rate or average of Assessee’s past three years’ assessed profit rates, excluding taxes collected on sales from gross receipts. Matter was remanded for fresh computation after granting opportunity of hearing, &  appeal was allowed for statistical purposes

FULL TEXT OF THE ORDER OF ITAT HYDERABAD

This appeal is filed by Ms. Yugendra Puppala (“the assessee”), feeling aggrieved by the order passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (“Ld. CIT(A)”) dated 18.06.2025 for the A.Y. 2015-16.

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Author Info

CA Vijayakumar Shetty
Qualification: CA in Practice
Company: Shetty & Co, Chartered Accountants, Mangalore
Location: Mangalore, Karnataka
Articles Published: 6,844

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