2019 (3) TMI 585

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....e assessee which were confirmed by the CIT (Appeals). 2. We have heard the learned Senior Counsel for the appellant assessee at considerable length. The facts that emerge from the Appeal is that the income tax authority had carried out search operation on various premises of the assessee during which incriminating documents were impounded and seized. These documents included a diary. Statements of the assessee were also recorded. One Sonal Parag - the associate of the assessee was also subjected to search, during search a diary was found. These diaries contained entries in relation to the cash receipts and payments by the assessee. The assessee was engaged in the activity of securing admissions for students in various academic institutio....

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....sessee. The Tribunal reduced the additions to 20% of the total cash payments by way of assessee's profit as against 25% estimated by Commissioner (Appeals) with respect to one of the years. In these appeals the assessee disputes the very foundation of the additions as well as estimation thereof. 5. Having heard the learned Senior Counsel for the appellant, we find that the entire issue is factual in nature. Two revenue authorities and the tribunal have concurrently come to the conclusion that the assessee had earned unaccounted income. Only question was of its estimation. The tribunal estimated the assessee's share of income at 20/25% of the total turn over. It may be that the Tribunal had adopted 25% commission for one year and ....