Return of income is not filed  under section 139 or in response to notice under section 148. CIT(A) after considering the remand report affirmed the addition. On appeal the Tribunal held since the deposits in the assessee’s bank account represented two kinds of receipts, i. e., as a commission agent and in respect of drip irrigation system under the scheme of the State Government, there could not be a single percentage of commission for both these activities. Hence, the matter is  remanded to the Assessing Officer with a direction to reconsider the issue and apply the appropriate rate for estimation of income.(AY.2015-16)