2019 (4) TMI 1936

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....e Revenue has filed this Appeal challenging the Judgment of Income Tax Appellate Tribunal. Following question was presented for our consideration; "Whether on the facts and in the circumstances of the case and in law, the Hon'ble Tribunal erred in restricting the addition of Rs. 370.69 lakhs made on account of unexplained cash credits u/s. 68 of the Act to 0.15% without appreciating that the....

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....h is also admitted by the Assessee during search. 4. In our opinion, the entire issue is based on facts. The estimation of the rate of commission of the Assesee would always be subject matter of some guesswork. No precise formula could be applied. The Tribunal having taken into consideration the relevant factors, has arrived at a certain percentage of commission that any such kind of activities ....