TMI Blog2008 (11) TMI 356X X X X Extracts X X X X X X X X Extracts X X X X ..... On appeal of the assessee, the Commissioner of Income-tax (Appeals) made further additions. The Tribunal directed determination of the net profit by applying a net profit rate of 12 percent. on contract receipt excluding the cost of material supplied by the department. Held that- the Tribunal proceeded on the basis that there may be unverifiable wages which may call for addition to income, but not ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... raise the following substantial question of law: "(i) Whether, on the facts and in the circumstances of the case, the learned Tribunal was right in law in directing to determine the net profit by applying a net profit rate of 12 per cent. on contract receipts of Rs. 91,65,025, excluding the cost of material supplied by the Department subject to allowability of salary and interest paid to the pa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the issue was considered by the Tribunal. While considering the issue of addition on account of unverifiable wages, the Tribunal considered it appropriate to apply reasonable rate of profit, which was assessed at the rate of 12 per cent. on contract receipts, excluding the material supplied by the Department. The Tribunal also relied upon its judgment in the case of Ess Ess Builders P. Ltd. (in I. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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