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Judgment
This assessee’s appeal for assessment year 2015-16, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1083999182(1), dated 23.12.2025 involving proceedings under section 147 r.w.s 144 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
Learned counsel representing assessee presses for its fourth substantive ground reading as under:
“On the facts and circumstantces of the case and in law, the CIT(A) erred in confirming the addition made by the assessing officer of Rs. 23,86,573/- i.e., at the rate 8 percent of total turnover of Rs. 2,98,32,158/- as alleged unexplained investment u/s 68 of the Act.”
Suffice to say, it has come on record that sole issue sought to be canvassed hereby is that of correctness of learned lower authorities assessing the assessee’s turnover @ 8% in assessment as upheld in the lower appellate discussion. It is in this factual backdrop that Mr. Yadav has filed a copy of the learned Assessing Officer’s assessment order itself dated 21.03.2022 for A.Y. 2016-17 assessing average NP @ 2.63% only in its hands which has gone unrebutted from the Revenue side. It is thus deemed appropriate that a lumpsump addition @ 2.63% in the assessee’s case than that in issue @ 8% would be just and proper with a rider that the same shall not be treated as a precedent. Necessary computation shall follow as per law.
This assessee’s appeal is partly allowed.