Bench: Shri M. Balaganeshm/S Shri Kaila Devi Ice & Cold Vs. Income Tax Officer, Storage Ward-4(4), 19-20, Adesh Nagar, Sheetla Agra Road, Khandari, Agra. (Appellant) (Respondent) Pan: Aazfs2787H Assessee By : Shri Rajesh Malhotra, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 03/02/2026

40A(3) and adverse conclusion drawn to justify the net profit rate of 25% is unjust, illegal and arbitrary. 8. That the appellant craves to add or alter any other ground of appeal as may be warranted.” 3. I have heard the rival submissions and perused the materials available on record. The assessee is a partnership firm engaged