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Section 145 of the Income-tax Act, 1961 - Method of Accounting - Estimation of project Where Tribunal determined income of assessee in transport business by applying net profit rate at 4.96 per cent comparing it with comparable cases as against income determined by Assessing Officer by applying occupancy rate based on field enquiries in case of assessee, High Court would not substitute its opinion for that of Tribunal [In favour of assessee] [Assessment year 2003-04] CIT v. Sandeep Bus Service (P.) Ltd. [2009] 316 ITR 244 (Punj. & Har.) Where the Tribunal determined income of the assessee in transport business by applying the net profit rate at 4.96 per cent comparing it with comparable cases as against income determined by the Assessing Officer by applying the occupancy rate based on the filed enquiries in the case of the assessee : Held that the revenue contended that keeping in view the comparative cases of the transporters showing better occupancy and income, the estimation made by the Tribunal in the case of the assessee was not fair. However, it did not dispute the fact that the routes on which the buses of the assessee were plying and that of the other transporters were different. The Tribunal in the facts and circumstances of the case had assessed the income of the assessee by applying net profit rate of 4.96 per cent on gross receipts. While examining the material placed on record in appellate jurisdiction under section 260A, this Court would not like to substitute its own opinion over and above the opinion expressed by the Tribunal by making estimation of the income as the same would not fall within the ambit of a substantial question of law. Savetha Saxena for the Appellant. JUDGMENT Rajesh Bindal, J.- The Revenue has filed the present appeal under section 260A of the Income-tax Act, 1961 (for short "the Act"), against the order passed by the Income-tax Appellate Tribunal, Amritsar Bench, Amritsar (for short "the Tribunal"), in I.T.A. No. 15 (ASR)/2007 and I.T.A. No. 63 (ASR)/2007, dated October 5, 2007, for the assessment year 2003-04, raising the following substantial question of law: "Whether, on the facts and in the circumstances of the case,…

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