SURESH KHANDELWAL,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 3, DELHI, DELHI

ITA 4201/DEL/2026Status: DisposedITAT Delhi12 August 2026AY 2023-2412 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that while the rejection of books of accounts under Section 145(3) was justified, the estimation of profit by the lower authorities was not based on sound reasoning or evidence. The Tribunal restricted the addition to a lower percentage of purchases, acknowledging the assessee's involvement in suspicious transactions but also noting the revenue's failure to provide specific evidence.

What were the facts?

The assessee's case was reopened under Section 147 based on allegations of bogus purchases and sales routed through shell entities, following a search operation on the Rajdhani Flour Mills Group. The Assessing Officer rejected the assessee's books of accounts under Section 145(3) and made an addition estimating profit at 2% of total sales.

What were the issues?

Whether the rejection of books of accounts and the estimation of profit by the Assessing Officer and CIT(A) were justified and based on proper evidence, and whether the assessment order was passed without proper jurisdiction.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 145(3),Section 132,Section 127(2)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCHES, “H” NEW DELHI

Before: SHRI SUDHIR PAREEK

Pronounced: 12.08.2026

PER AMITABH SHUKLA, AM

This bunch of three appeals filed by the assessee are directed against the separate orders of Ld. Commissioner of Income Tax (Appeals)-23, New Delhi, dated 11.03.2026 arising out of separate assessment orders passed by the Assistant Commissioner of Income tax, Central Circle-3, Delhi (‘the AO’) passed u/s 147 r.w.s. 144 of t

The order continues below.

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