In the result, the appeal of the assesse is allowed for statistical purpose

Bench: the Ld. CIT(A). The Ld.CIT(A) partly allowed the appeal filed by the assessee by directing the AO to -

194H of the Act was from "M/s Vodafone Idea Limited" from whom the data could be collected before completing the assessment u/s 147 read with section 144 of the Act. The Assessing Officer could easily compare the profitability of other distributors of the mobile service providers and reasonably estimate the profits of the assessee. Instead, she had seen only