ORDER

PER RAKESH MISHRA, ACCOUNTANT MEMBER:

This appeal filed by the assessee is against the order of the Commissioner of Income Tax (Appeals)-NFAC, Delhi [hereinafter referred to as Ld. 'CIT(A)'] passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2020-21 dated 18.11.2025.

2. The assessee is in appeal before the Tribunal raising the following grounds of appeal:

“1. That the order of the Ld. CIT(A), NFAC, dated 18.11.2025 is bad in law and on facts.

2. That the Ld. CIT(A) erred in sustaining the addition of ₹2,48,57,295/- without considering the statutory exemption available to the appellant u/s 10(26) of the Act.

3. That the Ld. CIT(A) erred in treating the entire bank credits of ₹9,94,29,182/- as turnover, ignoring that 70% thereof represents statutory levies (VAT and Excise) and only 30% is the basic value of sales.

4. That the Ld. CIT(A) erred in not appreciating that as per Government of Meghalaya Notification, the gross margin in bonded warehouses is fixed at 8% of basic value and net margin after expenses is only 2%.

5. That the estimation of profit @25% of gross credits is arbitrary, excessive, and contrary to law.

6. That the Ld. CIT(A)