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TMI Blog2013 (1) TMI 807X X X X Extracts X X X X X X X X Extracts X X X X ..... s services to the group companies in a centralised manner for the operating companies of the group which are engaged mainly in manufacture of automobile accessories. The services consists of liaison, market survey and management consultancy etc. During the course of assessment proceeding, it was, inter alia, observed by the A.O. that in the current year the total receipts of the assessee were ₹ 26,80,56,182/- and the corresponding expenses were ₹ 34,66,19,774/- , thus there was a loss from the business. The A.O. further observed that in earlier years, the percentage of total receipts has been consistently considered as income of the assessee from its business activities ignoring all the expenses incurred by it. However, the esti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... taking a mark-up on the cost, confirmed the addition made by the A.O. 4. Being aggrieved by the order of the ld. CIT(A) the assessee is in appeal before us taking following ground of appeal:- The learned CIT(A) erred in confirming the action of Assessing Officer of estimating the business income of ₹ 6,93,23,955/- by marking up the cost by 20%. It is pleaded that the action of Assessing Officer is entirely without any coherent reasons and is bad on facts and also in law and hence the assessment order needs to be quashed on this ground alone. 5. At the time of hearing the ld. Counsel for the assessee while referring to the earlier years combined order of the Tribunal for assessment years 1997-98, 1998-99, 2003-04, separate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 20% of the expenses incurred by the assessee without bringing any supporting material on record. Since the issue has not been examined properly, we are of the view that, in the interest of justice, the matter should go back to the file of the A.O. and accordingly we set aside the order passed by the Revenue authorities on this account and send back the matter to the file of the A.O. to decide the same afresh in the light of our observations hereinabove and according to law after providing reasonable opportunity of being heard to the assessee. The ground taken by the assessee is, therefore, partly allowed for statistical purpose. 8. In the result, appeal filed by the assessee stands partly allowed for statistical purpose. Order pronou ..... X X X X Extracts X X X X X X X X Extracts X X X X
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