Tribunal adjusts income estimation for assessee's appeal, aligning with business nature and market conditions.

The Tribunal partially allowed the assessee's appeal for AY 2012-13 and fully for AY 2017-18. It directed the estimation of income at 5% of gross receipts for both assessment years, aligning with previous decisions and considering the business nature and market conditions.

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Issues:
1. Addition of Rs. 17,66,735/- on estimate of profit on gross receipts and Rs. 7,37,935/- towards other income for AY 2012-13.
2. Estimate of business income for AY 2017-18.

Analysis:

Issue 1: AY 2012-13
- The assessee contested the addition of Rs. 17,66,735/- on gross receipts and Rs. 7,37,935/- towards other income made by the Ld. CIT(A).
- The Assessing Officer estimated income due to discrepancies between form 26AS and books of accounts, leading to the addition.
- Tribunal's previous decision for AY 2007-08 estimated income at 5% of gross receipts, which the assessee sought to follow.
- The Tribunal analyzed the nature of the business and upheld the assessee's contention, estimating income at 5% of gross receipts for AY 2012-13, aligning with previous decisions.

Issue 2: AY 2017-18
- The Assessing Officer added Rs. 28,52,083/- as business income due to lack of supporting vouchers and estimated income at 10% of receipts.
- The assessee argued for a lower estimate of 5% on gross receipts citing the nature of the business involving high competition and liquidity issues.
- Ld. CIT(A) referred to previous decisions and estimated income at 8% of gross receipts for AY 2017-18.
- The Tribunal, considering the business dynamics and past rulings, directed the income to be estimated at 5% of gross receipts for AY 2017-18, in line with the decision for AY 2012-13.

In conclusion, the Tribunal allowed the assessee's appeal in part for AY 2012-13 and fully for AY 2017-18, directing the estimation of income at 5% of gross receipts for both assessment years based on the nature of the business and market conditions.

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