Tribunal held that there was no understatement of receipts by the assessee.  Further, in first round of appeals no addition in this regard for called for by Tribunal and the same was not controverted by lower authorities. The net income from drama company as a percentage of gross receipts cannot be as high as has been held by CIT(A).  In absence of any comparable case put for the by the authorities below, the ad hoc addition sustained by CIT(A) cannot be justified.  (AY.  1995-96 to 1998-99)