No Section 271AAA penalty on ad-hoc addition based on average GP rate

M/s Ace Steel Fab (P) Ltd. Vs DCIT (ITAT Delhi)  In the present appeal, the only addition made in the income was of Rs.11,52,300/- on account of estimation of Gross Profit @ 68%. It is the contention of the assessee that the discrepancy in stock was due to malfunction in the ERP software. Though, this explanation was not accepted by the Assessing Officer, the assessee has demonstrated with evidence that due to malfunction of the software, the accounts could not be completed in time and that the assessee had to approach the Company Law Board with a petition to extend the date for adoption of a...