Allowing the appeal the Court held that the Tribunal , ought to have appreciated that only reasonable and proper gross profit rate was to be applied and the assessee was the only dealer who had entered into bulk purchases of timber with the State Forest Corporation. The returns of the subsequent years, i.e., 1989-90 to 1991-92 could not have been taken into account for computing the gross profit rate in respect of the assessment year 1986-87. Thus, the finding with regard to gross profit rate was based on surmises and conjectures and it had been arrived at in contravention of the directions contained in the earlier order passed by the Tribunal, which was upheld by the court and had attained finality. The orders passed by the Commissioner (Appeals) and the Tribunal were quashed. ( AY. 1986 -87)