9911796707
TMI Blog2024 (7) TMI 641X X X X Extracts X X X X X X X X Extracts X X X X ..... the purpose of determination of the rate of profit disclosed by the assessee. Normally, the best comparison to determine the net profit by the assessee would be earlier or the subsequent assessment years of the same assessee. In the present case, the impugned assessment year is the first year of assessee s business. A perusal of the facts also clearly shows that the assessee has shown the highest ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essee : Shri S.K.Sarangi, CA For the Revenue : Dr. Abani Kanta Nayak, CIT-DR ORDER PER BENCH : This is an appeal filed by the assessee against the order dated 01.03.2024, passed by the CIT(A), National Faceless Appeal Centre (NFAC), Delhi in DIN Order No.ITBA/NFAC/S/250/2023-24/1061268921(1). 2. It was submitted by the ld. AR that the assessee is engaged in the business of commission agent for pra ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3) r.w.s.263 of the Act on 01.09.2021, wherein the AO estimated the income of the assessee @8% by applying the provisions of Section 44AD of the Act on the turnover of Rs. 6,67,98,896/-. The AO also brought to tax the interest income earned by the assessee from the bank account. It was the submission that on appeal, the ld. CIT(A) though deleted the reference of Section 44AD of the Act by the AO, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... profit as adopted by the ld. AO and upheld by the ld. CIT(A) is reasonable. 5. We have considered the rival submissions. At the outset, ld. AR submitted that he does not want to challenge the addition representing the bank interest. Thus, ground raised by the assessee challenging the addition representing the bank interest is dismissed as withdrawn. 6. In regard to the issue of estimation of net p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on the total turnover of the assessee after reduction of the airport rent cost, thormocol sheet cost and truck rent cost as there is no possibility of assessee earning any income out of the said expenses. Consequently, the AO is directed to estimate the income of the assessee @2.75% on the total turnover of the assessee i.e. Rs. 5,63,82,203/- after reduction of the expenses regarding airport rent, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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