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Judgment
ORDER
These assessee’s twin appeals in ITA Nos. 219 & 220/Del/2026 and Stay Applications SA Nos. 13 & 14/Del/2026 for Assessment Years 2016-17 & 2017-18, arise against the CIT(A)/NFAC, Delhi’s DIN & order Nos. ITBA/NFAC/S/250/2025-26/10882531493(1) & 1082531974(1) dated 1 2.11.2025, in proceedings u/s 147 r.w.s. 144 of the Income Tax Act, 1961 (in short “the Act”), respectively.
Heard both the parties at length. Case files perused.
It transpires dur ing the course of hearing at the outset that the assessee/appe llant raises his identical so le substantive grievance directed against both the learned lower authorities respective assessment and lower appellate findings assessing his total credits or deposits; as the case may be , amounting to Rs.1,47,49,377/- and Rs.1,10,64,681; assessment year wise, respectively as assessable in the nature of his business income there by estimating NP thereupon @8%.
This is what leaves the assessee aggrieved.
That being the case, the Revenue could hardly dispute that the assessee has admittedly engaged in wholesale supply business of “Tello” i.e. animal fats in the name and style o f M/s T. S. Traders. There is further no dispute that the assessee’s business segment invo lves a highly or ganized sector wherein both the learned lower authorities have not even referred to the corresponding market comparables while estimating his NP @8% in issue. The facts also remains that the assessee all along has not discharge d his onus of proving very low NP in his business activity as we ll.
Be that as it may, this tribunal deems it appropriate in this factual backdrop that a lump sum NP estimation @2.5% in both these assessment years would be just and proper with a rider that the same shall not be treated as a prece dent. Or dered accor dingly. Necessary computation shall follow.
The assessee’s stay applications SA Nos. 13 & 14/Del/2026 are dismissed as rendered infructuous.
These assessee’s twin appeals ITA Nos. 219 & 220/Del/2026 are partly allowed and Stay Applications SA Nos. 13 & 14/Del/2026 are dismisse d in above terms. A copy o f this common order be placed in the respective case files.