9911796707
TMI Blog2017 (11) TMI 2069X X X X Extracts X X X X X X X X Extracts X X X X ..... estimated the net profit rate of the commission @ 2%, which according to the assessee was 0.15% - HELD THAT:- As per consistent with the view taken in various similar matters, we also uphold the rate of commission / net profit rate from such activity at 0.15%. Accordingly, this issue is decided in favour of the assessee. Expenses allowed as deductions - The assessee has stated before us that 50% ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... arisen in group concerns of the assessee before the Tribunal wherein the rate of commission has been accepted at 0.15%. The list of some of the ITAT decisions filed before us is as under: (i) M/s Goldstar Finvest P Ltd-ITAs 887 and 2699/M/2013, order dated 30.11.2015; (ii) M/s Mihir Agencies Pvt. Ltd. in ITAs 6435 to 6441/M/2012 vide order dated 06.01.2016; (iii) Alliance Intermediateries an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... action, it was found that the assessee and the Group companies of the assessee were engaged in the business of accommodation entries and laundering of black money. The managing director Mr. Mukesh Choksi himself was the mastermind behind formation of all these companies. Various other details and modus operandi have been noted by him along with the statement on oath of the assessee and the seized ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ir Agencies Pvt Ltd (supra) and on similar other decisions as relied before us, we find that the Tribunal has upheld the net profit rate of 0.15%. The relevant observation of the Tribunal in the case of M/s Mihir Agencies Pvt. Ltd is reproduced hereunder:- "7. We find that in the case of Gold Star Finvest Ltd, which is a sister concern of the assessee, on similar facts for the assessment year 20 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by the assessee was adjudicated by the Ld. CIT (A) and the Ld. CIT (A) has allowed Rs. 2,110/- out of Rs. 10,550/- of total expenses. Hence, the appeal was partly allowed. 8. We have heard the rival contentions of both the parties. The assessee has stated before us that 50% of the expenses should be allowed. We find that the Ld. CIT (A) has allowed 20% of the expenses on estimated basis ..... X X X X Extracts X X X X X X X X Extracts X X X X
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