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ITAT upheld the CIT(A)'s approach but dismissed Additional Ground No.1A, finding the Assessing Officer had relied on incriminating material seized from common premises of the group, thereby validating use of those materials. The Tribunal observed the AO's gross commission determination (1.28%) was excessive and, having regard to ITSC findings in the group's case, directed the AO to make a limited adjustment to the assessee's net profit by applying half the rate adopted by the ITSC. The resultant additional net profit rate is 0.0375% over the income declared in the return. Appeal disposed of against the revenue.
ITAT upheld the CIT(A)'s approach but dismissed Additional Ground No.1A, finding the Assessing Officer had relied on incriminating material seized from common premises of the group, thereby validating use of those materials. The Tribunal observed the AO's gross commission determination (1.28%) was excessive and, having regard to ITSC findings in the group's case, directed the AO to make a limited adjustment to the assessee's net profit by applying half the rate adopted by the ITSC. The resultant additional net profit rate is 0.0375% over the income declared in the return. Appeal disposed of against the revenue.
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