TMI Blog2019 (3) TMI 1845X X X X Extracts X X X X X X X X Extracts X X X X ..... ion to 0.15% - HELD THAT:- Tribunal referred to its own decision in case of the Assessee's sister concern and held that the appropriate rate of commission should be 0.15% which is also admitted by the Assessee during search. 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1. These Appeals are filed by the Revenue to challenge the Judgment of Income Tax Appellate Tribunal. Following question is presented for our consideration. Whether on the facts and in the circumstances of the case and in law, the Hon'ble ITAT was correct in restricting the commission / rate of net profit 0.15% as against the 2% adopted by the AO on the basis of admission made by the di ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n of the rate of commission of the Assesee would always be subject matter of some guesswork. No precise formula could be applied. The 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. 5. The Revenue also ..... X X X X Extracts X X X X X X X X Extracts X X X X
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