CIT v. President Industries

225 ITR 47Supreme Court of India#6315 most cited

What is CIT v. President Industries authority for?

When undisclosed sales are discovered, only the profits attributable to those sales can be brought to tax, not the entire sales amount.

18

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2023 to 2025.

Also referred to as

CIT v. President Industries · section 69d · undisclosed sales · estimation of profit · net profit rate · turnover · gross profit · unaccounted purchases · section 153a · section 143(3)

Sections most often in play

Section 143(3)Section 147Section 148Section 153ASection 153CSection 40A(3)Section 69C

Issues it is cited on

section 69dtrade creditorssection 158bbsection 69brejection of books of accountsection 153a(1)(b)mistake apparent from recordloose paperssection 153a(1)section 145(3)documents seizedshare application money

Judgments citing CIT v. President Industries

SHIVAM READYMIX PRIVATE LIMITED,JAIPUR vs. ACIT, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 166/JPR/2025[2012-13]Status: DisposedITAT Jaipur06 Aug 2025AY 2012-13
For Appellant: Shri Tarun Mittal, CA &For Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 143(3)Section 147Section 148Section 40A(3)Section 69C

…wherein in ITSSA No.\n53/JP/06, Hon'ble bench has held that in the case of unaccounted sales income\nis to be estimated by applying a reasonable Net profit rate.\nAlso reliance is placed on the following judicial pronouncements:\nCIT Vs. President Industries 225 ITR 47 (SC):\nEntire sales cannot be taxed only profits could be added.\n[2023] 146 taxmann.com 467 (SC) Kuwer Fibres (P.) Ltd. v. Commissioner of\nIncome-tax*\nSection 69B, read with sections 158B and 132, of the Income-tax Act, 1961\nUndisclosed investments (Unaccounted purchases) - Block periods 1-4-1985 to\n20-3-1996 - Search and seizures proceedings…

DCIT, CC-2, JAIPUR vs. SHRI JITENDRA KUMAR AGARWAL, JAIPUR

In the result, appeal of the assessee is dismissed and that of the revenue is also stands dismissed

ITA 181/JPR/2020[2017-18]Status: DisposedITAT Jaipur07 Jun 2023AY 2017-18

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &
Section 132Section 143Section 143(3)Section 145(3)Section 68

…Ltd. wherein in ITA No. 53/JP/06, Hon’ble bench has hold that in the case of unaccounted sales income is to be estimated by applying a reasonable Net profit rate. Also reliance is placed on the following judicial pronouncements: CIT Vs. President Industries 225 ITR 47 (SC): Entire sales cannot be taxed only profits could be added. ITO Vs Somsons&Co.148 TAXMAN 21(Asr.,ITAT): Estimation of profit – AO cannot estimate income which do not bear any relationship with the past history of the case. ITO, Ward 45(3), Kolkata Vs. ManiklalDey ITA No. 2436 /Kol/2016 (ITAT-Kol): Turnover includes cost or purchases and gross…

DCIT, CC-2, JAIPUR vs. SHRI JITENDRA KUMAR AGARWAL, JAIPUR

In the result, based on the discussion so recorded here in above both

ITA 180/JPR/2020[2016-17]Status: DisposedITAT Jaipur07 Jun 2023AY 2016-17

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &
Section 132Section 143Section 143(3)Section 145(3)Section 68

…d. wherein in ITSSA No. 53/JP/06, Hon’ble bench has held that in the case of unaccounted sales income is to be estimated by applying a reasonable Net profit rate. Also reliance is placed on the following judicial pronouncements: CIT Vs. President Industries 225 ITR 47 (SC): Entire sales cannot be taxed only profits could be added. ITO Vs Somsons & Co. 148 TAXMAN 21(Asr., ITAT): Estimation of profit – AO cannot estimate income which do not bear any relationship with the past history of the case. ITO, Ward 45(3), Kolkata Vs. ManiklalDey ITA No. 2436 /Kol/2016 (ITAT-Kol): Turnover includes cost or purchases and…

DCIT, CC-2, JAIPUR vs. SHRI JITENDRA KUMAR AGARWAL, JAIPUR

In the result, based on the discussion so recorded here in above both

ITA 179/JPR/2020[2015-16]Status: DisposedITAT Jaipur07 Jun 2023AY 2015-16

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &
Section 132Section 143Section 143(3)Section 145(3)Section 68

…d. wherein in ITSSA No. 53/JP/06, Hon’ble bench has held that in the case of unaccounted sales income is to be estimated by applying a reasonable Net profit rate. Also reliance is placed on the following judicial pronouncements: CIT Vs. President Industries 225 ITR 47 (SC): Entire sales cannot be taxed only profits could be added. ITO Vs Somsons & Co. 148 TAXMAN 21(Asr., ITAT): Estimation of profit – AO cannot estimate income which do not bear any relationship with the past history of the case. ITO, Ward 45(3), Kolkata Vs. ManiklalDey ITA No. 2436 /Kol/2016 (ITAT-Kol): Turnover includes cost or purchases and…

DCIT, CC-2, JAIPUR vs. SHRI JITENDRA KUMAR AGARWAL, JAIPUR

In the result, based on the discussion so recorded here in above both

ITA 178/JPR/2020[2013-14]Status: DisposedITAT Jaipur07 Jun 2023AY 2013-14

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &
Section 132Section 143Section 143(3)Section 145(3)Section 68

…d. wherein in ITSSA No. 53/JP/06, Hon’ble bench has held that in the case of unaccounted sales income is to be estimated by applying a reasonable Net profit rate. Also reliance is placed on the following judicial pronouncements: CIT Vs. President Industries 225 ITR 47 (SC): Entire sales cannot be taxed only profits could be added. ITO Vs Somsons & Co. 148 TAXMAN 21(Asr., ITAT): Estimation of profit – AO cannot estimate income which do not bear any relationship with the past history of the case. ITO, Ward 45(3), Kolkata Vs. ManiklalDey ITA No. 2436 /Kol/2016 (ITAT-Kol): Turnover includes cost or purchases and…

DCIT, CC-2, JAIPUR vs. M/S. ROYAL JEWELLERS, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 176/JPR/2020[2016-17]Status: DisposedITAT Jaipur07 Jun 2023AY 2016-17

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

…d. wherein in ITSSA No. 53/JP/06, Hon’ble bench has held that in the case of unaccounted sales income is to be estimated by applying a reasonable Net profit rate. Also reliance is placed on the following judicial pronouncements: CIT Vs. President Industries 225 ITR 47 (SC): Entire sales cannot be taxed only profits could be added. ITO Vs Somsons& Co. 148 TAXMAN 21 (Asr., ITAT): Estimation of profit – AO cannot estimate income which do not bear any relationship with the past history of the case. ITO, Ward 45(3), Kolkata Vs. Maniklal Dey ITA No. 2436/Kol/2016 (ITAT-Kol): Turnover includes cost or purchases and…

DCIT, CC-2, JAIPUR vs. M/S. ROYAL JEWELLERS, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 175/JPR/2020[2015-16]Status: DisposedITAT Jaipur07 Jun 2023AY 2015-16

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

…d. wherein in ITSSA No. 53/JP/06, Hon’ble bench has held that in the case of unaccounted sales income is to be estimated by applying a reasonable Net profit rate. Also reliance is placed on the following judicial pronouncements: CIT Vs. President Industries 225 ITR 47 (SC): Entire sales cannot be taxed only profits could be added. ITO Vs Somsons& Co. 148 TAXMAN 21 (Asr., ITAT): Estimation of profit – AO cannot estimate income which do not bear any relationship with the past history of the case. ITO, Ward 45(3), Kolkata Vs. Maniklal Dey ITA No. 2436/Kol/2016 (ITAT-Kol): Turnover includes cost or purchases and…

DCIT, CC-2, JAIPUR vs. M/S. ROYAL JEWELLERS, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 174/JPR/2020[2014-15]Status: DisposedITAT Jaipur07 Jun 2023AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

…d. wherein in ITSSA No. 53/JP/06, Hon’ble bench has held that in the case of unaccounted sales income is to be estimated by applying a reasonable Net profit rate. Also reliance is placed on the following judicial pronouncements: CIT Vs. President Industries 225 ITR 47 (SC): Entire sales cannot be taxed only profits could be added. ITO Vs Somsons& Co. 148 TAXMAN 21 (Asr., ITAT): Estimation of profit – AO cannot estimate income which do not bear any relationship with the past history of the case. ITO, Ward 45(3), Kolkata Vs. Maniklal Dey ITA No. 2436/Kol/2016 (ITAT-Kol): Turnover includes cost or purchases and…

M/S. ROYAL JEWELLERS,JAIPUR vs. DCIT, CENTRAL CIRCLE, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 115/JPR/2020[2016-17]Status: DisposedITAT Jaipur07 Jun 2023AY 2016-17

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

…d. wherein in ITSSA No. 53/JP/06, Hon’ble bench has held that in the case of unaccounted sales income is to be estimated by applying a reasonable Net profit rate. Also reliance is placed on the following judicial pronouncements: CIT Vs. President Industries 225 ITR 47 (SC): Entire sales cannot be taxed only profits could be added. ITO Vs Somsons& Co. 148 TAXMAN 21 (Asr., ITAT): Estimation of profit – AO cannot estimate income which do not bear any relationship with the past history of the case. ITO, Ward 45(3), Kolkata Vs. Maniklal Dey ITA No. 2436/Kol/2016 (ITAT-Kol): Turnover includes cost or purchases and…

M/S. ROYAL JEWELLERS,JAIPUR vs. DCIT, CENTRAL CIRCLE, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 114/JPR/2020[2015-16]Status: DisposedITAT Jaipur07 Jun 2023AY 2015-16

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

…d. wherein in ITSSA No. 53/JP/06, Hon’ble bench has held that in the case of unaccounted sales income is to be estimated by applying a reasonable Net profit rate. Also reliance is placed on the following judicial pronouncements: CIT Vs. President Industries 225 ITR 47 (SC): Entire sales cannot be taxed only profits could be added. ITO Vs Somsons& Co. 148 TAXMAN 21 (Asr., ITAT): Estimation of profit – AO cannot estimate income which do not bear any relationship with the past history of the case. ITO, Ward 45(3), Kolkata Vs. Maniklal Dey ITA No. 2436/Kol/2016 (ITAT-Kol): Turnover includes cost or purchases and…

M/S. ROYAL JEWELLERS,JAIPUR vs. DCIT, CENTRAL CIRCLE, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 113/JPR/2020[2014-15]Status: DisposedITAT Jaipur07 Jun 2023AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

…d. wherein in ITSSA No. 53/JP/06, Hon’ble bench has held that in the case of unaccounted sales income is to be estimated by applying a reasonable Net profit rate. Also reliance is placed on the following judicial pronouncements: CIT Vs. President Industries 225 ITR 47 (SC): Entire sales cannot be taxed only profits could be added. ITO Vs Somsons& Co. 148 TAXMAN 21 (Asr., ITAT): Estimation of profit – AO cannot estimate income which do not bear any relationship with the past history of the case. ITO, Ward 45(3), Kolkata Vs. Maniklal Dey ITA No. 2436/Kol/2016 (ITAT-Kol): Turnover includes cost or purchases and…

SHRI JITENDRA KUMAR AGARWAL,JAIPUR vs. DCIT, CENTRAL CIRCLE-2, JAIPUR

In the result, appeal of the assessee is dismissed and that of the revenue is also stands dismissed

ITA 112/JPR/2020[2017-18]Status: DisposedITAT Jaipur07 Jun 2023AY 2017-18

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &
Section 132Section 143Section 143(3)Section 145(3)Section 68

…Ltd. wherein in ITA No. 53/JP/06, Hon’ble bench has hold that in the case of unaccounted sales income is to be estimated by applying a reasonable Net profit rate. Also reliance is placed on the following judicial pronouncements: CIT Vs. President Industries 225 ITR 47 (SC): Entire sales cannot be taxed only profits could be added. ITO Vs Somsons&Co.148 TAXMAN 21(Asr.,ITAT): Estimation of profit – AO cannot estimate income which do not bear any relationship with the past history of the case. ITO, Ward 45(3), Kolkata Vs. ManiklalDey ITA No. 2436 /Kol/2016 (ITAT-Kol): Turnover includes cost or purchases and gross…

SHRI JITENDRA KUMAR AGARWAL,JAIPUR vs. DCIT, CENTRAL CIRCLE-2, JAIPUR

In the result, based on the discussion so recorded here in above both

ITA 111/JPR/2020[2016-17]Status: DisposedITAT Jaipur07 Jun 2023AY 2016-17

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &
Section 132Section 143Section 143(3)Section 145(3)Section 68

…d. wherein in ITSSA No. 53/JP/06, Hon’ble bench has held that in the case of unaccounted sales income is to be estimated by applying a reasonable Net profit rate. Also reliance is placed on the following judicial pronouncements: CIT Vs. President Industries 225 ITR 47 (SC): Entire sales cannot be taxed only profits could be added. ITO Vs Somsons & Co. 148 TAXMAN 21(Asr., ITAT): Estimation of profit – AO cannot estimate income which do not bear any relationship with the past history of the case. ITO, Ward 45(3), Kolkata Vs. ManiklalDey ITA No. 2436 /Kol/2016 (ITAT-Kol): Turnover includes cost or purchases and…

SHRI JITENDRA KUMAR AGARWAL,JAIPUR vs. DCIT, CENTRAL CIRCLE-2, JAIPUR

In the result, based on the discussion so recorded here in above both

ITA 110/JPR/2020[2015-16]Status: DisposedITAT Jaipur07 Jun 2023AY 2015-16

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &
Section 132Section 143Section 143(3)Section 145(3)Section 68

…d. wherein in ITSSA No. 53/JP/06, Hon’ble bench has held that in the case of unaccounted sales income is to be estimated by applying a reasonable Net profit rate. Also reliance is placed on the following judicial pronouncements: CIT Vs. President Industries 225 ITR 47 (SC): Entire sales cannot be taxed only profits could be added. ITO Vs Somsons & Co. 148 TAXMAN 21(Asr., ITAT): Estimation of profit – AO cannot estimate income which do not bear any relationship with the past history of the case. ITO, Ward 45(3), Kolkata Vs. ManiklalDey ITA No. 2436 /Kol/2016 (ITAT-Kol): Turnover includes cost or purchases and…

SHRI JITENDRA KUMAR AGARWAL,JAIPUR vs. DCIT, CENTRAL CIRCLE-2, JAIPUR

In the result, based on the discussion so recorded here in above both

ITA 109/JPR/2020[2014-15]Status: DisposedITAT Jaipur07 Jun 2023AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &
Section 132Section 143Section 143(3)Section 145(3)Section 68

…d. wherein in ITSSA No. 53/JP/06, Hon’ble bench has held that in the case of unaccounted sales income is to be estimated by applying a reasonable Net profit rate. Also reliance is placed on the following judicial pronouncements: CIT Vs. President Industries 225 ITR 47 (SC): Entire sales cannot be taxed only profits could be added. ITO Vs Somsons & Co. 148 TAXMAN 21(Asr., ITAT): Estimation of profit – AO cannot estimate income which do not bear any relationship with the past history of the case. ITO, Ward 45(3), Kolkata Vs. ManiklalDey ITA No. 2436 /Kol/2016 (ITAT-Kol): Turnover includes cost or purchases and…

SHRI JITENDRA KUMAR AGARWAL,JAIPUR vs. DCIT, CENTRAL CIRCLE-2, JAIPUR

In the result, based on the discussion so recorded here in above both

ITA 108/JPR/2020[2013-14]Status: DisposedITAT Jaipur07 Jun 2023AY 2013-14

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &
Section 132Section 143Section 143(3)Section 145(3)Section 68

…d. wherein in ITSSA No. 53/JP/06, Hon’ble bench has held that in the case of unaccounted sales income is to be estimated by applying a reasonable Net profit rate. Also reliance is placed on the following judicial pronouncements: CIT Vs. President Industries 225 ITR 47 (SC): Entire sales cannot be taxed only profits could be added. ITO Vs Somsons & Co. 148 TAXMAN 21(Asr., ITAT): Estimation of profit – AO cannot estimate income which do not bear any relationship with the past history of the case. ITO, Ward 45(3), Kolkata Vs. ManiklalDey ITA No. 2436 /Kol/2016 (ITAT-Kol): Turnover includes cost or purchases and…

SHRI JITENDRA KUMAR AGARWAL,JAIPUR vs. DCIT, CENTRAL CIRCLE-2, JAIPUR

In the result, based on the discussion so recorded here in above both

ITA 107/JPR/2020[2012-13]Status: DisposedITAT Jaipur07 Jun 2023AY 2012-13

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &
Section 132Section 143Section 143(3)Section 145(3)Section 68

…d. wherein in ITSSA No. 53/JP/06, Hon’ble bench has held that in the case of unaccounted sales income is to be estimated by applying a reasonable Net profit rate. Also reliance is placed on the following judicial pronouncements: CIT Vs. President Industries 225 ITR 47 (SC): Entire sales cannot be taxed only profits could be added. ITO Vs Somsons & Co. 148 TAXMAN 21(Asr., ITAT): Estimation of profit – AO cannot estimate income which do not bear any relationship with the past history of the case. ITO, Ward 45(3), Kolkata Vs. ManiklalDey ITA No. 2436 /Kol/2016 (ITAT-Kol): Turnover includes cost or purchases and…

SHRI JITENDRA KUMAR AGARWAL,JAIPUR vs. DCIT, CENTRAL CIRCLE-2, JAIPUR

In the result, based on the discussion so recorded here in above both

ITA 106/JPR/2020[2011-12]Status: DisposedITAT Jaipur07 Jun 2023AY 2011-12

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &
Section 132Section 143Section 143(3)Section 145(3)Section 68

…d. wherein in ITSSA No. 53/JP/06, Hon’ble bench has held that in the case of unaccounted sales income is to be estimated by applying a reasonable Net profit rate. Also reliance is placed on the following judicial pronouncements: CIT Vs. President Industries 225 ITR 47 (SC): Entire sales cannot be taxed only profits could be added. ITO Vs Somsons & Co. 148 TAXMAN 21(Asr., ITAT): Estimation of profit – AO cannot estimate income which do not bear any relationship with the past history of the case. ITO, Ward 45(3), Kolkata Vs. ManiklalDey ITA No. 2436 /Kol/2016 (ITAT-Kol): Turnover includes cost or purchases and…

CIT v. President Industries (225 ITR 47) — Cited in 18 Judgments | BharatTax