102 ITR 281 41-44 4 Rajesh Mahajan v. CIT (2010) 320 ITR 74 45-49 5 Arti Ship Breaking v. DIT

92 ITR 287High Court1973#5411 most cited

What is 102 ITR 281 41-44 4 Rajesh Mahajan v. CIT (2010) 320 ITR 74 45-49 5 Arti Ship Breaking v. DIT authority for?

Previous assessment orders can be used as good material or evidence for computing the assessment for the current year. An assessment based on inadequate material is liable to be set aside.

22

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2025.

Also referred to as

Vrajlal Manilal and Co. v. CIT · 1973 · 92 ITR 287 · assessment based on inadequate material · previous assessment orders as evidence · estimation of profit

Sections most often in play

Section 132Section 133ASection 145(3)Section 148Section 292CSection 37(1)Section 40(a)(ia)Section 132(1)

Issues it is cited on

section 132(3)section 124(1)section 124(3)(a)section 127(1)section 127(2)section 63section 124(3)section 124percentage completion methoddumb documentssection 120section 132(4a)

Judgments citing 102 ITR 281 41-44 4 Rajesh Mahajan v. CIT (2010) 320 ITR 74 45-49 5 Arti Ship Breaking v. DIT

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

ITA 509/JPR/2025[2021-22]Status: DisposedITAT Jaipur12 Nov 2025AY 2021-22
For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

…Aggarwalla v. Union of India (1965) 56 ITR 14\n29-35\n3\nAjantha Industries v. CBDT (1976) 102 ITR 281\n35-40\n4\nRajesh Mahajan v. CIT (2010) 320 ITR 74\n41-44\n5\nArti Ship Breaking v. DIT (2010) 189 Taxman 50\n45-49\n6\nVrajlal Manilal & Co. v. CIT (1973) 92 ITR 287\n50-56\n11. On 17.09.2025 when confronted to the Id. DR on the issue that all the\nnotices, correspondence and even address in Form no. 26AS shows the\naddress of the assessee at Delhi then how the Notice u/s.153C was issued\nby the Income Tax Officer, Ward 1(3), Jaipur and whether any PAN transfer\nrequest was made to Delhi PCIT or that of the Id…

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

ITA 508/JPR/2025[2020-21]Status: DisposedITAT Jaipur12 Nov 2025AY 2020-21

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

…iram Aggarwalla v. Union of India (1965) 56 ITR 14 29-35 2 35-40 3 Ajantha Industries v. CBDT (1976) 102 ITR 281 41-44 4 Rajesh Mahajan v. CIT (2010) 320 ITR 74 45-49 5 Arti Ship Breaking v. DIT (2010) 189 Taxman 50 50-56 6 Vrajlal Manilal & Co. v. CIT (1973) 92 ITR 287 11. On 17.09.2025 when confronted to the ld. DR on the issue that all the notices, correspondence and even address in Form no. 26AS shows the address of the assessee at Delhi then how the Notice u/s. 153C was issued by the Income Tax Officer, Ward 1(3), Jaipur and whether any PAN transfer request was made to Delhi PCIT or that of the ld.AO and a…

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

ITA 507/JPR/2025[A.Y. 2018-19]Status: DisposedITAT Jaipur12 Nov 2025

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

…iram Aggarwalla v. Union of India (1965) 56 ITR 14 29-35 2 35-40 3 Ajantha Industries v. CBDT (1976) 102 ITR 281 41-44 4 Rajesh Mahajan v. CIT (2010) 320 ITR 74 45-49 5 Arti Ship Breaking v. DIT (2010) 189 Taxman 50 50-56 6 Vrajlal Manilal & Co. v. CIT (1973) 92 ITR 287 11. On 17.09.2025 when confronted to the ld. DR on the issue that all the notices, correspondence and even address in Form no. 26AS shows the address of the assessee at Delhi then how the Notice u/s. 153C was issued by the Income Tax Officer, Ward 1(3), Jaipur and whether any PAN transfer request was made to Delhi PCIT or that of the ld.AO and a…

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

ITA 506/JPR/2025[2016-17]Status: DisposedITAT Jaipur12 Nov 2025AY 2016-17

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

…iram Aggarwalla v. Union of India (1965) 56 ITR 14 29-35 2 35-40 3 Ajantha Industries v. CBDT (1976) 102 ITR 281 41-44 4 Rajesh Mahajan v. CIT (2010) 320 ITR 74 45-49 5 Arti Ship Breaking v. DIT (2010) 189 Taxman 50 50-56 6 Vrajlal Manilal & Co. v. CIT (1973) 92 ITR 287 11. On 17.09.2025 when confronted to the ld. DR on the issue that all the notices, correspondence and even address in Form no. 26AS shows the address of the assessee at Delhi then how the Notice u/s. 153C was issued by the Income Tax Officer, Ward 1(3), Jaipur and whether any PAN transfer request was made to Delhi PCIT or that of the ld.AO and a…

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

ITA 505/JPR/2025[2015-16]Status: DisposedITAT Jaipur12 Nov 2025AY 2015-16

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

…iram Aggarwalla v. Union of India (1965) 56 ITR 14 29-35 2 35-40 3 Ajantha Industries v. CBDT (1976) 102 ITR 281 41-44 4 Rajesh Mahajan v. CIT (2010) 320 ITR 74 45-49 5 Arti Ship Breaking v. DIT (2010) 189 Taxman 50 50-56 6 Vrajlal Manilal & Co. v. CIT (1973) 92 ITR 287 11. On 17.09.2025 when confronted to the ld. DR on the issue that all the notices, correspondence and even address in Form no. 26AS shows the address of the assessee at Delhi then how the Notice u/s. 153C was issued by the Income Tax Officer, Ward 1(3), Jaipur and whether any PAN transfer request was made to Delhi PCIT or that of the ld.AO and a…

SURESH KUMAR REDDY KRISHNAPURAM,KURNOOL vs. ACIT., CENTRAL CIRCLE - 2(3), HYDERABAD

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 538/HYD/2025[2021-22]Status: DisposedITAT Hyderabad20 Aug 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…ment based on no material at all or based on inadequate material is, therefore, bad in law and liable to be set aside. The issue relating to method of accounting or estimation of profit was also considered in the case of Vrajlal Manilal and Co. vs., CIT[1973] 92 ITR 287 (Madhya Pradesh). The Hon’ble Madhya Pradesh High Court while considering an identical issue has held that, “the previous orders of assessment would form good material or good evidence for the purpose of computing assessment for the year in question. The Coordinate Bench of ITAT, Hyderabad, in the case of R.K.Township Constructions Pvt. Ltd vs., D…

SURESH KUMAR REDDY KRISHNAPURAM,KURNOOL vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 537/HYD/2025[2020-21]Status: DisposedITAT Hyderabad20 Aug 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…ment based on no material at all or based on inadequate material is, therefore, bad in law and liable to be set aside. The issue relating to method of accounting or estimation of profit was also considered in the case of Vrajlal Manilal and Co. vs., CIT[1973] 92 ITR 287 (Madhya Pradesh). The Hon’ble Madhya Pradesh High Court while considering an identical issue has held that, “the previous orders of assessment would form good material or good evidence for the purpose of computing assessment for the year in question. The Coordinate Bench of ITAT, Hyderabad, in the case of R.K.Township Constructions Pvt. Ltd vs., D…

SKANDHANSHI INFRA PROJECTS,KURNOOL vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 534/HYD/2025[2019-20]Status: DisposedITAT Hyderabad20 Aug 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…ment based on no material at all or based on inadequate material is, therefore, bad in law and liable to be set aside. The issue relating to method of accounting or estimation of profit was also considered in the case of Vrajlal Manilal and Co. vs., CIT[1973] 92 ITR 287 (Madhya Pradesh). The Hon’ble Madhya Pradesh High Court while considering an identical issue has held that, “the previous orders of assessment would form good material or good evidence for the purpose of computing assessment for the year in question. The Coordinate Bench of ITAT, Hyderabad, in the case of R.K.Township Constructions Pvt. Ltd vs., D…

SKANDA DEVELOPERS & BUILDERS,KURNOOL vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 533/HYD/2025[2019-20]Status: DisposedITAT Hyderabad20 Aug 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…ment based on no material at all or based on inadequate material is, therefore, bad in law and liable to be set aside. The issue relating to method of accounting or estimation of profit was also considered in the case of Vrajlal Manilal and Co. vs., CIT[1973] 92 ITR 287 (Madhya Pradesh). The Hon’ble Madhya Pradesh High Court while considering an identical issue has held that, “the previous orders of assessment would form good material or good evidence for the purpose of computing assessment for the year in question. The Coordinate Bench of ITAT, Hyderabad, in the case of R.K.Township Constructions Pvt. Ltd vs., D…

SKANDHANSHI DEVELOPERS,KURNOOL vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 527/HYD/2025[2020-21]Status: DisposedITAT Hyderabad20 Aug 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…ment based on no material at all or based on inadequate material is, therefore, bad in law and liable to be set aside. The issue relating to method of accounting or estimation of profit was also considered in the case of Vrajlal Manilal and Co. vs., CIT[1973] 92 ITR 287 (Madhya Pradesh). The Hon’ble Madhya Pradesh High Court while considering an identical issue has held that, “the previous orders of assessment would form good material or good evidence for the purpose of computing assessment for the year in question. The Coordinate Bench of ITAT, Hyderabad, in the case of R.K.Township Constructions Pvt. Ltd vs., D…

SKANDA INFRA PROJECTS,KURNOOL vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 522/HYD/2025[2019-20]Status: DisposedITAT Hyderabad20 Aug 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…ment based on no material at all or based on inadequate material is, therefore, bad in law and liable to be set aside. The issue relating to method of accounting or estimation of profit was also considered in the case of Vrajlal Manilal and Co. vs., CIT[1973] 92 ITR 287 (Madhya Pradesh). The Hon’ble Madhya Pradesh High Court while considering an identical issue has held that, “the previous orders of assessment would form good material or good evidence for the purpose of computing assessment for the year in question. The Coordinate Bench of ITAT, Hyderabad, in the case of R.K.Township Constructions Pvt. Ltd vs., D…

SKANDA INFRA PROJECTS INDIA PRIVATE LIMITED,KURNOOL vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 517/HYD/2025[2022-23]Status: DisposedITAT Hyderabad20 Aug 2025AY 2022-23

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…ment based on no material at all or based on inadequate material is, therefore, bad in law and liable to be set aside. The issue relating to method of accounting or estimation of profit was also considered in the case of Vrajlal Manilal and Co. vs., CIT[1973] 92 ITR 287 (Madhya Pradesh). The Hon’ble Madhya Pradesh High Court while considering an identical issue has held that, “the previous orders of assessment would form good material or good evidence for the purpose of computing assessment for the year in question. The Coordinate Bench of ITAT, Hyderabad, in the case of R.K.Township Constructions Pvt. Ltd vs., D…

SKANDA INFRA PROJECTS INDIA PRIVATE LIMITED,KURNOOL vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 514/HYD/2025[2019-20]Status: DisposedITAT Hyderabad20 Aug 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…ment based on no material at all or based on inadequate material is, therefore, bad in law and liable to be set aside. The issue relating to method of accounting or estimation of profit was also considered in the case of Vrajlal Manilal and Co. vs., CIT[1973] 92 ITR 287 (Madhya Pradesh). The Hon’ble Madhya Pradesh High Court while considering an identical issue has held that, “the previous orders of assessment would form good material or good evidence for the purpose of computing assessment for the year in question. The Coordinate Bench of ITAT, Hyderabad, in the case of R.K.Township Constructions Pvt. Ltd vs., D…

ACIT., CENTRAL CIRCLE-2(3), HYDERABAD vs. SKANDHANSHI INFRA PROJECTS INDIA PVT. LTD., BANGALORE

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 310/HYD/2025[2021-22]Status: DisposedITAT Hyderabad20 Aug 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…ment based on no material at all or based on inadequate material is, therefore, bad in law and liable to be set aside. The issue relating to method of accounting or estimation of profit was also considered in the case of Vrajlal Manilal and Co. vs., CIT[1973] 92 ITR 287 (Madhya Pradesh). The Hon’ble Madhya Pradesh High Court while considering an identical issue has held that, “the previous orders of assessment would form good material or good evidence for the purpose of computing assessment for the year in question. The Coordinate Bench of ITAT, Hyderabad, in the case of R.K.Township Constructions Pvt. Ltd vs., D…

ACIT., CENTRAL CIRCLE-2(3), HYDERABAD vs. SKANDHANSHI INFRA PROJECTS INDIA PVT. LTD., BANGALORE

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 308/HYD/2025[2019-20]Status: DisposedITAT Hyderabad20 Aug 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…ment based on no material at all or based on inadequate material is, therefore, bad in law and liable to be set aside. The issue relating to method of accounting or estimation of profit was also considered in the case of Vrajlal Manilal and Co. vs., CIT[1973] 92 ITR 287 (Madhya Pradesh). The Hon’ble Madhya Pradesh High Court while considering an identical issue has held that, “the previous orders of assessment would form good material or good evidence for the purpose of computing assessment for the year in question. The Coordinate Bench of ITAT, Hyderabad, in the case of R.K.Township Constructions Pvt. Ltd vs., D…

M/S BHIVARAM PANNALAL KUMAWAT,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR

Appeal are disposed off and all the appeals of the

ITA 69/JPR/2021[2012-13]Status: DisposedITAT Jaipur29 Mar 2022AY 2012-13

Bench: Us By The Department. The Facts As Well As Issues, Are More Or Less Involving The Disallowance Of Labour Expenses & Therefore, These Twelve Appeals Were Head

For Appellant: Shri P.C. Parwal, CAFor Respondent: Shri Sanjay Dhariwal, CIT
Section 132(4)Section 143(3)Section 153A

…ly rejected, the income has to be estimated andin making the estimate of such income, the best record alongwith other things will become the relevant material as held by the Hon'ble Madhya Pradesh High Court in the case of VrajlalManilal& Company Vs. CIT(1973)92 ITR 287(MP). (xv) Now coming to the estimation as noted above, the question which remains iswhether the basis of addition made by the AO is fair and reasonable on the facts of thecase. The AO has estimated gross profit by disallowing 15% of the aforesaid labourexpenses which on the facts appears to be arbitrary. (xvi) Therefore in view of the aforesaid…

DCIT, CC-3, JAIPUR vs. M/S BHIVARAM PANNALAL KUMAWAT, JAIPUR

Appeal are disposed off and all the appeals of the

ITA 117/JPR/2021[ 2013-14]Status: DisposedITAT Jaipur29 Mar 2022

Bench: Us By The Department. The Facts As Well As Issues, Are More Or Less Involving The Disallowance Of Labour Expenses & Therefore, These Twelve Appeals Were Head

For Appellant: Shri P.C. Parwal, CAFor Respondent: Shri Sanjay Dhariwal, CIT
Section 132(4)Section 143(3)Section 153A

…ly rejected, the income has to be estimated andin making the estimate of such income, the best record alongwith other things will become the relevant material as held by the Hon'ble Madhya Pradesh High Court in the case of VrajlalManilal& Company Vs. CIT(1973)92 ITR 287(MP). (xv) Now coming to the estimation as noted above, the question which remains iswhether the basis of addition made by the AO is fair and reasonable on the facts of thecase. The AO has estimated gross profit by disallowing 15% of the aforesaid labourexpenses which on the facts appears to be arbitrary. (xvi) Therefore in view of the aforesaid…

SRI AJIT PRASAD DEY,BANKURA vs. ITO, WARD - 3(1), BANKURA, BANKURA

In the result, the appeal of the assessee is partly allowed

ITA 2054/KOL/2017[2012-13]Status: DisposedITAT Kolkata05 Sept 2018AY 2012-13

Bench: Hon’Ble Shri M.Balaganesh, Am & Hon’Ble Shri S.S.Viswanethra Ravi, Jm] I.T.A No. 2054/Kol/2017 Assessment Year : 2012-13 Shri Ajit Prasad Dey -Vs- Ito, Ward-3(1), Bankura . [Pan: Adapd 9381 J] (Appellant) (Respondent)

For Appellant: Shri Soumitra Chowdhury, AdvocateFor Respondent: Shri I. Jamir, Addl. CIT
Section 142(1)Section 144

…al years was 1.84%. We find that the average of the net profit works out to 1.54%. The assessee during the year had disclosed the net profit of 0.76%. The Hon’ble Madhya Pradesh High Court had also held in the case of Brajlal Manilal & Co. vs. CIT reported in 92 ITR 287 and in yet another decision of Madhya Pradesh High Court Indore Bench in the case of Moorji Udhavji vs. CIT reported in 145 ITR 575 had held that earlier year profit percentage should be the basis or adoption of profit percentage in the year under appeal. In view of past history of the assessee as tabulated supra and in view of aforesaid decisions…

M/S SHIVHARE ASSOCIATES,GWALIOR vs. A.C.I.T., RANGE-1, GWALIOR

In the result, the appeals of the assessee are partly allowed

ITA 48/AGR/2015[2011-12]Status: DisposedITAT Agra16 May 2018AY 2011-12

Bench: Shri A.D. Jain & Dr. Mitha Lal Meenam/S Shivhare Associates, Jcit, Range-1, 44, Sindh Bihar, Nadi Gate, Vs. Gwalior Gwalior Pan Abbfs 6377 G

For Appellant: Shri K.C. Agarwal, AdvocateFor Respondent: Shri Waseem Arshad, Sr. DR And
Section 145(3)

…or arriving at the view that past history is the best guide to work out or estimate profit where book profit is, not believable, we derive authority from the Hon’ble jurisdictional M.P High Court Judgement in the case of ‘Vrajlal Manilal & Co. Vs CIT’, (1973) 92 ITR 287 (M.P) holding that “Section 145 of the Income-tax Act, 1961 Method of accounting - Estimation of profit - Assessment year 1957-58 - Whether previous orders of assessment, although they may even be best judgment assessments, would form good material or good evidence for purpose of computing income of assessment year in question - Held, yes.” 26. On…

M/S SHIVHARE ASSOCIATES,GWALIOR vs. J.C.I.T., RANGE-1, GWALIOR

In the result, the appeals of the assessee are partly allowed

ITA 47/AGR/2015[2010-11]Status: DisposedITAT Agra16 May 2018AY 2010-11

Bench: Shri A.D. Jain & Dr. Mitha Lal Meenam/S Shivhare Associates, Jcit, Range-1, 44, Sindh Bihar, Nadi Gate, Vs. Gwalior Gwalior Pan Abbfs 6377 G

For Appellant: Shri K.C. Agarwal, AdvocateFor Respondent: Shri Waseem Arshad, Sr. DR And
Section 145(3)

…or arriving at the view that past history is the best guide to work out or estimate profit where book profit is, not believable, we derive authority from the Hon’ble jurisdictional M.P High Court Judgement in the case of ‘Vrajlal Manilal & Co. Vs CIT’, (1973) 92 ITR 287 (M.P) holding that “Section 145 of the Income-tax Act, 1961 Method of accounting - Estimation of profit - Assessment year 1957-58 - Whether previous orders of assessment, although they may even be best judgment assessments, would form good material or good evidence for purpose of computing income of assessment year in question - Held, yes.” 26. On…

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