9911796707
TMI Blog2019 (9) TMI 613X X X X Extracts X X X X X X X X Extracts X X X X ..... impugned order of the ITAT shows that this is a second round of litigation. ITAT has explained how the fixing of the percentage at 2.25% by the AO was based on noting of some loose sheets which were seized during a search operation. The reliability of these notings are themselves in dispute. ITAT has on a consideration of the entire facts and circumstances and considering that different rates are ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... question sought to be urged by the Revenue is whether the ITAT has arbitrarily reduced the percentage of commission on the accommodation entries provided allegedly by the Assessee from 2.25 % to 0.5%. 2. A perusal of the impugned order of the ITAT shows that this is a second round of litigation. The ITAT has explained how the fixing of the percentage at 2.25% by the Assessing Officer was based o ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
