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2005 (11) TMI 38 - HC - Income TaxChallenge to best judgment assessment - The appellate authority had not disclosed as to why it has not taken in to consideration the trading and profit and loss account submitted by the petitioner and on what basis the computation is made. On the other hand as reflected from the order, the basis of computation of profit at 9 per cent, is general and casual. The revisional authority-also rejected the petitioner's prayer to reduce the net profit rate without assigning any reasons as to how the rate of 9 per cent, is just and reasonable. - In view of the aforesaid, the orders passed by the appellate authority and the revisional authority are held to be arbitrary to the extent they upheld the rate of 9 per cent, and are, therefore, quashed. The matter is remitted to the appellate authority to reconsidered as to the rate which can be applied while estimating net profits
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