2023 (2) TMI 643

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....wing substantial question of law: Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal is right in upholding the order of the Commissioner of Income Tax (Appeals) estimating the income of the assessee at 4% of the turn-over on the basis of the earlier year assessment orders, when the assessee has not maintained the Books of Accounts and has not audited his ....

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....fficer, who proceeded to make and determine the income on the basis of the estimation by adding 8% to the income reported as per Section 44-AB of the Income Tax Act, resulting in enhancement of the income liable to tax. 3. Now, we find that the order in appeal, namely the order of the appellate authority, dated 12.10.2022 is primarily one relating to estimation and thus, essentially a question of....

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.... percentage (%) declared by the assessee Income declared by the assesssee Profit determined u/s 143(3) 1 2015-16 41,81,21,750 3% 1,25,43,653 3% 2 2014-15 22,63,98,010 3% 67,91,940 3.50% 3 2013-14 14,07,09,573 4% 56,28,383   4 2012-13 13,71,29,706 4% 54,85,188   8. The assessment year under consideration is 2016-17. In the assessment year 2015-16, the assessee ....