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ITAT Panaji Applies 8% on Unaccounted Sales, Rejects Section 115BBE
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Income Tax Appellate Tribunal, Panajitax

ITAT Panaji Applies 8% on Unaccounted Sales, Rejects Section 115BBE

September 10, 2026

The ITAT Panaji has determined that an 8% profit margin is applicable to unaccounted bullion sales, thereby rejecting Section 115BBE. The ruling validates normal commercial practices over stringent penal provisions.

ITAT Panaji Applies 8% on Unaccounted Sales, Rejects Section 115BBE

The ITAT Panaji has upheld a decision to levy tax at an 8% profit rate on unaccounted sales of bullion, while simultaneously rejecting the application of Section 115BBE in this context. This decision follows the assessment of ₹48.54 lakh under Section 69A, which addresses unaccounted income.

In reviewing the case, the tribunal noted that the nature of the business and the reasonable profit percentage substantially influenced the determination of tax obligations. Rather than resorting to punitive measures, the ITAT embraced a more balanced approach by aligning taxation with conventional profit estimations.

For practitioners, this ruling reinforces the necessity to evaluate the nature of income and offers a precedent that stands against rigid applications of the tax code, especially concerning unaccounted income classified as business profits.

Citations

  • ITAT Panaji (2026) TaxGuru
Practice Areas:tax
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