9911796707
TMI Blog2008 (8) TMI 787X X X X Extracts X X X X X X X X Extracts X X X X ..... the Act"), against the order passed by the Income-tax Appellate Tribunal, Amritsar Bench, Amritsar (for short " the Tribunal"), in I. T. A. No. 15 (ASR)/2007 and I.T.A. No. 63 (ASR)/2007, dated October 5, 2007, for the assessment year 200304, raising the following substantial question of law: "Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was just ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Act was issued to the assessee on November 29, 2004. Finding a number of discrepancies in the books of account maintained by the assessee, the same were rejected and estimation of the income of the assessee was made considering the occupancy rate of 67 percent The assessee had shown gross receipts of Rs. 1,45,97,757 whereas receipt on the basis of 67 percent occupancy came to be Rs. 1,75,24,687. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed for estimation of the net profit of the assessee at the rate of 4.96 percent of the gross receipts and in terms thereof net income of the assessee was determined as Rs. 8,43,207 as against the net loss of Rs. 5,25,000 shown by the assessee. Learned counsel for the Revenue contended that keeping in view the comparative cases of the transporters showing better occupancy and income, the estimati ..... X X X X Extracts X X X X X X X X Extracts X X X X
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