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ITAT Reduces Profit Estimation to 4% as 8% Rate Ignored Audited Books & Past Margins

Case Law Details

TaxGuru Citation
2026 taxguru.in 6641
Case Name
Padmanaban Prabaharan Vs ITO (ITAT Chennai)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2016-17
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Padmanaban Prabaharan Vs ITO (ITAT Chennai)

The appeal before the Income Tax Appellate Tribunal (ITAT), Chennai, arose from the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), for Assessment Year 2016-17.

The assessee challenged the estimation of income at 8% of turnover. There was a delay of 107 days in filing the appeal before the Tribunal. The assessee explained that he had earlier conducted export business at Dindigul and had relied on his previous Chartered Accountant to handle tax matters. Due to communication gaps and fee disputes with the earlier representative, he remained unaware of the appellate proceedings and the dismissal of his appeal. After shifting business operations to Chennai and obtaining the case records in September 2025, the matter was entrusted to a new representative in January 2026. The Tribunal accepted the explanation, held that sufficient cause existed for the delay, condoned it, and proceeded to decide the appeal on merits.

The assessee was engaged in the business of Custom House Clearing Agency services. Based on information relating to customs shipping bills showing turnover/export receipts of ₹1,23,47,366, reassessment proceedings were initiated under section 148 on the ground that income chargeable to tax had escaped assessment. In response, the assessee filed a return declaring total income of ₹2,31,293 as net profit from the disclosed turnover.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 19,689

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