2016 (10) TMI 1179

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....f appeal: "The grounds of appeal mentioned herein below are wi thout prejudice to one another. 1 . The Ld AO erred in computing the amount of Accommodation turnover at Rs. 24,89,60,272/- , instead of Rs. 24,16,32,566/- , despite accepting the bifurcated figures of genuine turnover and accommodation turnover provided by the appellant , thus adopting the figure in flated by Rs. 73,27,706/- of accommodation turnover as against the correct figure of such turnover. The CIT (A) erred in confirming it.  2. The Ld AO erred in adopting the rate of 3% for estimating the income of the appel lant on impugned accommodation turnover wi thout br inging any comparable case on record, as well as rejecting the rate of 1% declared by the appellan....

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....The assessee, before us, has not disputed that it was indulged in providing accommodation bills to certain parties. However, it has been submitted that the estimation of profits at the rate of 3% were very excessive. It was also explained that out of the total turnover of Rs. 32.3 crores, the genuine turnover of the actual business carried out was only Rs. 8.2 crores and profit there from has been declared at Rs. 82,75,831/- which has accordingly been taxed as business income of the assessee. The Ld. A.R. has further submitted that the assessee has declared the income of the accommodation bills at the rate of 1% of the turnover which was actually received by the assessee. That the AO in the impugned assessment order himself has mentioned t....