TMI Blog2002 (11) TMI 738X X X X Extracts X X X X X X X X Extracts X X X X ..... ue for assessment year 1992-93 and is directed against the order of Commissioner (Appeals), Raj. III, Jaipur dated 6-2-1995. 2. CO No. 11/JDPR/99 has been preferred by assessee in respect of the above appeal of revenue. 3. We have heard the arguments of both the sides and also perused the records. 4. First we take up revenue s appeal. The revenue has taken the sole ground disputing the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to Rs. 95,400 implying change of tyres on trucks and tyres but had not explained as to what the assessee did of the old tyres, as the assessee had neither shown the sale of old tyres nor were the same shown in the closing stock. Relying on Assessing Officer s order, the ld. DR of revenue has contended that the Assessing Officer also considered this aspect of expenses while determining the appropr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sessee from Bikaner, the assessee s Head Office at Bikaner and all the Officers who award/allot the contract works also have their Head Offices at Bikaner. He has also contended that the fall in profit rate, in the year under consideration, has been due to the reason, among others, that during this year there has been substantial increase in assessee s contract receipts, and that the assessee exec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 87, the Tribunal held the profit rate of 9 per cent to be reasonable, we consider the conclusion/finding of ld. Commissioner (Appeals) in treating the profit rate of 9.3 per cent, as shown by assessee in the peculiar facts and circumstances of this particular year, to be quite proper and justified. We, therefore, decline to interfere with the same. 6. In the result the revenue s above appeal i ..... X X X X Extracts X X X X X X X X Extracts X X X X
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