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2019 (4) TMI 1936 - HC - Income TaxUnexplained cash credits u/s. 68 - AO adopted the rate of commission of 2% on the total turnover, which order the CIT (A) confirmed - Tribunal reduced the rate of commission to 0.15% - HELD THAT:- The entire issue is based on facts. The estimation of the rate of commission of the Assessee would always be subject matter of some guesswork. No precise formula could be applied. Tribunal having taken into consideration the relevant factors, has arrived at a certain percentage of commission that any such kind of activities could be expected to be derived from. This does not give rise to any substantial question of law. Revenue also disputes the expenditure allowed by the Tribunal on such activities. Here also, for the same reasons cited above, in our opinion, no question of law arises.
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