2010 (12) TMI 1227 - AT - Income Tax

Summary

Issues involved: Appeal by Revenue against CIT(A) order on grounds related to income estimation.

Estimation of Income:
During assessment, discrepancies found in accounts. AR agreed to income estimation. AO estimated income at 12.5% on contract receipts and added 25% of certain expenditure. CIT(A) accepted assessee's contention, deleted addition, and directed AO to accept declared profit. Revenue appealed, claiming AR admitted discrepancies and agreed to income estimation. Assessee's counsel argued AR never agreed to specific percentages. Tribunal found AR admitted discrepancies but not profit percentage. Directed AO to estimate net profit at 6.5% of gross contract receipts, citing lack of comparable cases for AO's estimation at 12.5%. No further allowance permitted.

Conclusion:
Tribunal partly allowed revenue's appeal, directing revised net profit estimation at 6.5% on gross contract receipts. No infirmity found in CIT's order regarding self-made vouchers. Decision pronounced on 27.12.2010.