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TMI Blog2004 (7) TMI 313X X X X Extracts X X X X X X X X Extracts X X X X ..... lved in appeal and the cross-objection is common and arises from the order of the same CIT(A), these were heard together and are being disposed of by this consolidated order for the sake of convenience. 2. The only effective issue raised in this appeal is that the learned CIT(A) was not justified in reducing the addition from Rs. 1,20,400 to Rs. 20,400 made on account of low GP rate. The facts o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing the provisions of s. 145(2). Various defects/discrepancies pointed out by the AO were duly explained before the CIT(A) by way of written submissions. It was further pointed out that the AO had wrongly held that net profit rate for the assessment year under reference shown at 18.86 per cent was lower than the net profit rate of the asst. yr. 1993-94 shown at 21.9 per cent. It was pointed out th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eal before us. 3. The learned Departmental Representative did not advance any specific arguments except relying on the order of AO. 4. The learned counsel for the assessee, on the other hand, heavily relied on the order of the CIT(A) reiterating the submissions made before the authorities below. He particularly drew our attention to p. 5 of the paper book where net profit rate before deduction ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ve and unreasonable. He wrongly worked out the net profit rate in comparison to earlier assessment year without considering the interest liability, which was higher than earlier year. In fact, before allowing deduction of interest claimed by the assessee, net profit rate for the assessment year under reference was higher than earlier assessment year. Even if book results are rejected by the AO, th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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