assistance to the Assessing Officer to work out credits on "peak theory" basis. Detailed charts were submitted which were verified by the Department ... from the impounded books. The Department worked out credits on peak theory basis amounting to Rs. 1,42,846 as on October
Settlement Commission directed the Revenue to check the
calculation on "peak credit theory" but without receiving
comment, the decoding was made by treating ... Rule 9 Report thus "peak
credit theory" should have been applied. The "theory of peak
credit" has not been applied
report dated 17.7.2003 stated that the plea
of telescoping or the peak theory was put forth by the assessee for the first time
before ... objection of the Assessing Officer that the
plea based on the peak theory was an additional evidence. According to him, there
was no additional evidence
computing the undisclosed income
of the assessee by applying the "peak theory". The computation
of the peak cash ... Iron Steels have been covered by the peak theory, details of which
have been given at pages 620 to 633 of the SOF filed
facts and circumstances, where the ld. CIT
(A) while accepting the peak credit theory for deposit
and withdrawals in the same account, has acted ... unable to
see any logic in reference to the peak credit theory in the
present case; and the decision in Ranjeet Kumar Sethia
(supra
Representative after granting partial
relief of ` 5 lakh without appreciating the `Peak Theory'
duly accepted by this Hon'ble High Court ... wherein the peak being ` 8,71,131/- thus the
addition having been based on suspicion without any
adverse evidence against the appellant and conversely
without
case, the
Ld. CIT(A) is right in directing to apply peak theory on Cash
Deposits in Bank Account, particularly when the cash was
deposited ... dated 17.11.2016, partly allowed the appeal. It was
held that the peak theory should be applied for additions to be made in the
hands
further submitted that since the Assessing Officer had adopted peak
theory for the assessment year 2006-07, the same was to be followed
submitted for addition on
account of unexplained investment basing upon the
peak theory?"
3. Brief facts of the case are that the respondent-
assessee ... making addition under the head
of unaccounted investment (peak) at
Rs.22,39,196/- and Estimation of Gross Profit on
account of unaccounted purchases
that
the assessee company had derived the profits by adopting the
Peak Theory. The A.O. held that when Annexure-A-7 reflects
the actual
