Net profit rate on undisclosed business receipts restricted to 7.8% on consistent past results and unrebutted facts.

Net profit rate applied to undisclosed business receipts was restricted to 7.8% because the assessee's disclosed business results and past data consistently supported that rate, and the Revenue did not rebut that factual position. The higher 12% rate was therefore not sustained on the material on record, and the assessment of undisclosed receipts was correspondingly reduced.

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Issues: Whether the net profit rate applied to the assessee's undisclosed business receipts required reduction from 12% to 7.8%.

Analysis: The assessee's disclosed business results and past data were relied upon to show that the net profit rate consistently came to 7.8%. The Revenue did not rebut this factual position.

Conclusion: The net profit rate on the undisclosed receipts was restricted to 7.8%, and the appeal was partly allowed.

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