Sec. 147 & 148 of Income Tax Act, 1961—Reassessment- One turnover can be taxed in the hands of two different assessee one being partnership firm and another being proprietary concern of the assessee , therefore, AO is directed to delete the addition in the hands of the assessee to the extent of the turnover considered in case of partnership firm and since there is no change in the business model of the partnership firm as well as the business of the assessee, AO was directed to adopt the profit ratio of 8% as net profit on the gross receipts. - RAJESH GUPTA V/s ITO - [2020] 82 ITR (TRIB) 517 (ITAT-DELHI)