2025 (10) TMI 568

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....T ORDER PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER: This appeal filed by the assessee is directed against the order dated 30.09.2024 passed by the ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [NFAC], Delhi for the assessment year 2013-14. 2. At the outset, we note that the Assessing Officer received information that the assessee made cash deposit of Rs..1,03,60,8....

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....6,460/- during the year under consideration. The assessee has not submitted profit and loss account to ascertain the income from trading activity of the assessee and commission activity. In the absence of the classification of the income earned by the assessee, the Assessing Officer treated the entire credit at Rs..2,35,66,460/- as total turnover of the assessee and estimated net profit at 8% of t....

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....mittee and also submitted the confirmation given by the Superintendent of Marketing Committee issued on 08.03.2023 and also attached list containing detailed breakup of crop, date of purchase, no. of kgs/bags, party for whom purchased and the amount of purchase, which was duly attested by the Superintendent of Marketing Committee. She submits that the assessee received commission of 1% of the tota....

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....g activity of the assessee and from commission activity. However, we find that the estimation of 8% of total amount credited, which was confirmed by the ld. CIT(A), appears to be in higher side and there is no scope for earning commission at 8%. Thus, in the interest of natural justice, we hold that estimation of 3% of total amount credited would be fair and reasonable. Accordingly, the Assessing ....