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2019 (9) TMI 613 - HC - Income TaxCommission on the accommodation entries provided by assessee - ITAT reduced the percentage from 2.25 % to 0.5% in second round of litigation - HELD THAT:- The impugned order of the ITAT shows that this is a second round of litigation. ITAT has explained how the fixing of the percentage at 2.25% by the AO was based on noting of some loose sheets which were seized during a search operation. The reliability of these notings are themselves in dispute. ITAT has on a consideration of the entire facts and circumstances and considering that different rates are charged in different transactions formed the view that 0.5% should be taken as a reasonable rate of profit/commissioner in such activities. This Court fails to appreciate how the said order of the ITAT gives rise to any substantial question of law. Moreover, this is the second round of litigation and it has to end at some point. The Court sees no reason to interfere with the impugned order of the ITAT.
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