2013 (1) TMI 807

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....nd business facilities to its group companies. It also renders various services to the group companies in a centralised manner for the operating companies of the group which are engaged mainly in manufacture of automobile accessories. The services consists of liaison, market survey and management consultancy etc. During the course of assessment proceeding, it was, inter alia, observed by the A.O. that in the current year the total receipts of the assessee were Rs. 26,80,56,182/- and the corresponding expenses were Rs. 34,66,19,774/- , thus there was a loss from the business. The A.O. further observed that in earlier years, the percentage of total receipts has been consistently considered as income of the assessee from its business activitie....

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....e A.O. has estimated the income in a rational manner by taking a mark-up on the cost, confirmed the addition made by the A.O. 4. Being aggrieved by the order of the ld. CIT(A) the assessee is in appeal before us taking following ground of appeal:- "The learned CIT(A) erred in confirming the action of Assessing Officer of estimating the business income of Rs. 6,93,23,955/- by marking up the cost by 20%. It is pleaded that the action of Assessing Officer is entirely without any coherent reasons and is bad on facts and also in law and hence the assessment order needs to be quashed on this ground alone." 5. At the time of hearing the ld. Counsel for the assessee while referring to the earlier years combined order of the Tribunal ....