CIT v. Rayala Corporation (P) Ltd. (Mad)

215 ITR 883High Court1995#2927 most cited

What is CIT v. Rayala Corporation (P) Ltd. (Mad) authority for?

A best judgment assessment is valid if the estimate made by the Assessing Officer is not arbitrary, has a nexus with discovered facts, and cannot be questioned. The Assessing Officer is considered the best judge of the situation.

40

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2025.

Also referred to as

CIT v. Rayala Corporation (P) Ltd. · 215 ITR 883 · best judgment assessment · arbitrary estimate · nexus with facts · Assessing Officer is best judge · rejection of books of accounts · Section 145(3)

Sections most often in play

Section 1961Section 131Section 132Section 143(3)Section 153CSection 37Section 133ASection 145

Issues it is cited on

circular tradingprohibited by lawsummons under section 131section 10(23c)(iiiab)rule of consistencybest judgment assessmentrejection of books of accountsection 30section 145(3)documents seizedprofits and gains of business or professionsection 145

Judgments citing CIT v. Rayala Corporation (P) Ltd. (Mad)

SATAVAHANA UNIVERSITY,KARIMNAGAR vs. INCOME TAX OFFICER, WARD-2, KARIMNAGAR

ITA 1526/HYD/2025[2019-2020]Status: DisposedITAT Hyderabad10 Dec 2025AY 2019-2020

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1524/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Satavahana University, Vs. Income Tax Officer, Karimnagar. Ward-2, Karimnagar. Pan: Aaajs4101N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri E. Phalguna Kumar, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr आ.अपी.सं /Ita No.1525/Hyd/2025 (िनधा"रण वष"/Assessment Year:2018-19) Satavahana University, Vs. Income Tax Officer, Karimnagar. Ward-2, Karimnagar. Pan: Aaajs4101N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri E. Phalguna Kumar, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr आ.अपी.सं /Ita No.1526/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2019-20) Satavahana University, Vs. Income Tax Officer, Karimnagar. Ward-2, Karimnagar. Pan: Aaajs4101N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri E. Phalguna Kumar, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement: Satavahana University Vs. Ito आदेश / Order

For Appellant: Shri E. Phalguna Kumar, CAFor Respondent: Dr. Narendra Kumar Naik
Section 10Section 10(230)Section 115BSection 139Section 147Section 148Section 148ASection 151ASection 250Section 69A

…by the AO. Therefore, AO passed an order u/s 147 r.w.s 144B of the Act. In view of the above, it is very clear that the AO has rightly passed the said order as per law. Reliance is placed on the following case laws 1. CIT Vs. Rayala Corporation (P) Ltd. (Mad) 215 ITR 883 2. CIT Vs. P.P. Khader Haji (Ker) 234 ITR 461 4.1.3 Accordingly ground of appeal no. 1 raised by the appellant is hereby dismissed. 4.2 Ground no. 2 - Non granting of exemption claimed u/s 10(23C)(iiiab)of the Act 4.2.1 On perusal of the records it is seen that the appellant had neither filed return of income u/s 139(1) not 148. Therefore, exempt…

SATAVAHANA UNIVERSITY,KARIMNAGAR vs. INCOME TAX OFFICER, WARD-2, KARIMNAGAR

ITA 1525/HYD/2025[2018-2019]Status: DisposedITAT Hyderabad10 Dec 2025AY 2018-2019

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1524/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Satavahana University, Vs. Income Tax Officer, Karimnagar. Ward-2, Karimnagar. Pan: Aaajs4101N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri E. Phalguna Kumar, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr आ.अपी.सं /Ita No.1525/Hyd/2025 (िनधा"रण वष"/Assessment Year:2018-19) Satavahana University, Vs. Income Tax Officer, Karimnagar. Ward-2, Karimnagar. Pan: Aaajs4101N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri E. Phalguna Kumar, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr आ.अपी.सं /Ita No.1526/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2019-20) Satavahana University, Vs. Income Tax Officer, Karimnagar. Ward-2, Karimnagar. Pan: Aaajs4101N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri E. Phalguna Kumar, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement: Satavahana University Vs. Ito आदेश / Order

For Appellant: Shri E. Phalguna Kumar, CAFor Respondent: Dr. Narendra Kumar Naik
Section 10Section 10(230)Section 115BSection 139Section 147Section 148Section 148ASection 151ASection 250Section 69A

…by the AO. Therefore, AO passed an order u/s 147 r.w.s 144B of the Act. In view of the above, it is very clear that the AO has rightly passed the said order as per law. Reliance is placed on the following case laws 1. CIT Vs. Rayala Corporation (P) Ltd. (Mad) 215 ITR 883 2. CIT Vs. P.P. Khader Haji (Ker) 234 ITR 461 4.1.3 Accordingly ground of appeal no. 1 raised by the appellant is hereby dismissed. 4.2 Ground no. 2 - Non granting of exemption claimed u/s 10(23C)(iiiab)of the Act 4.2.1 On perusal of the records it is seen that the appellant had neither filed return of income u/s 139(1) not 148. Therefore, exempt…

SATAVAHANA UNIVERSITY,KARIMNAGAR vs. INCOME TAX OFFICER, WARD-2, KARIMNAGAR

ITA 1524/HYD/2025[2016-2017]Status: DisposedITAT Hyderabad10 Dec 2025AY 2016-2017

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1524/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Satavahana University, Vs. Income Tax Officer, Karimnagar. Ward-2, Karimnagar. Pan: Aaajs4101N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri E. Phalguna Kumar, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr आ.अपी.सं /Ita No.1525/Hyd/2025 (िनधा"रण वष"/Assessment Year:2018-19) Satavahana University, Vs. Income Tax Officer, Karimnagar. Ward-2, Karimnagar. Pan: Aaajs4101N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri E. Phalguna Kumar, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr आ.अपी.सं /Ita No.1526/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2019-20) Satavahana University, Vs. Income Tax Officer, Karimnagar. Ward-2, Karimnagar. Pan: Aaajs4101N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri E. Phalguna Kumar, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement: Satavahana University Vs. Ito आदेश / Order

For Appellant: Shri E. Phalguna Kumar, CAFor Respondent: Dr. Narendra Kumar Naik
Section 10Section 10(230)Section 115BSection 139Section 147Section 148Section 148ASection 151ASection 250Section 69A

…by the AO. Therefore, AO passed an order u/s 147 r.w.s 144B of the Act. In view of the above, it is very clear that the AO has rightly passed the said order as per law. Reliance is placed on the following case laws 1. CIT Vs. Rayala Corporation (P) Ltd. (Mad) 215 ITR 883 2. CIT Vs. P.P. Khader Haji (Ker) 234 ITR 461 4.1.3 Accordingly ground of appeal no. 1 raised by the appellant is hereby dismissed. 4.2 Ground no. 2 - Non granting of exemption claimed u/s 10(23C)(iiiab)of the Act 4.2.1 On perusal of the records it is seen that the appellant had neither filed return of income u/s 139(1) not 148. Therefore, exempt…

ACIT CENTRAL CIRCLE 7 (1), MUMBAI vs. LLOYDS METALS AND ENERGY LIMITED, MUMBAI

In the result, for all the

ITA 3094/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Nov 2025AY 2018-19
Section 143(3)Section 145Section 153C

…er considering the overall facts and circumstances, the\nassessee's income is considered @ 5% of Rs557001849/- The\nabove estimate gets further vindicated by a judgement of the\nHonourable Madras Court in the case of CIT vs. Rayala\nCorporation (P) Ltd. (Mad) 215 ITR 883, wherein the Hon'ble\nCourt adjudicated that best judgement assessment is valid so\nlong as the estimate made by Assessing officer is not arbitrary\nand has nexus with facts discovered and the same cannot be\nquestioned. It also adjudicated the Assessing Officer is the best\njudge of the situation.\n\nThus, rejection of books of accounts is justi…

ACIT CENTRAL CIRCLE 7 (1), MUMBAI vs. LLOYDS METALS AND ENERGY LIMITED, MUMBAI

ITA 3080/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Nov 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRIISH AGRAWAL (Accountant Member)

Section 143(3)Section 145Section 153C

…After considering the overall facts and circumstances, the assessee's income is considered @ 5% of Rs557001849/- The above estimate gets further vindicated by a judgement of the Honourable Madras Court in the case of CIT vs. Rayala Corporation (P) Ltd. (Mad) 215 ITR 883, wherein the Hon'ble Court adjudicated that best judgement assessment is valid so long as the estimate made by Assessing officer is not arbitrary and has nexus with facts discovered and the same cannot be questioned. It also adjudicated the Assessing Officer is the best judge of the situation. Thus, rejection of books of accounts is justified. Ac…

ACIT CENTRAL CIRCLE 7 (1), MUMBAI vs. LLOYDS METALS AND ENERGY LIMITED, MUMBAI

ITA 3079/MUM/2025[2019-20]Status: DisposedITAT Mumbai27 Nov 2025AY 2019-20

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRESH AGRAWAL (Accountant Member)

Section 143(3)Section 145Section 153C

…After considering the overall facts and circumstances, the assessee's income is considered @ 5% of Rs557001849/- The above estimate gets further vindicated by a judgement of the Honourable Madras Court in the case of CIT vs. Rayala Corporation (P) Ltd. (Mad) 215 ITR 883, wherein the Hon'ble Court adjudicated that best judgement assessment is valid so long as the estimate made by Assessing officer is not arbitrary and has nexus with facts discovered and the same cannot be questioned. It also adjudicated the Assessing Officer is the best judge of the situation. Thus, rejection of books of accounts is justified. Ac…

ACIT CENTRAL CIRCLE 7 (1), MUMBAI vs. LLOYDS METALS AND ENERGY LIMITED, MUMBAI

In the result, for all the

ITA 3078/MUM/2025[2016-17]Status: DisposedITAT Mumbai27 Nov 2025AY 2016-17
Section 143(3)Section 145Section 153C

…er considering the overall facts and circumstances, the\nassessee's income is considered @ 5% of Rs557001849/- The\nabove estimate gets further vindicated by a judgement of the\nHonourable Madras Court in the case of CIT vs. Rayala\nCorporation (P) Ltd. (Mad) 215 ITR 883, wherein the Hon'ble\nCourt adjudicated that best judgement assessment is valid so\nlong as the estimate made by Assessing officer is not arbitrary\nand has nexus with facts discovered and the same cannot be\nquestioned. It also adjudicated the Assessing Officer is the best\njudge of the situation.\n\nThus, rejection of books of accounts is justi…

ACIT CENTRAL CIRCLE 7 (1), MUMBAI vs. LLOYDS METALS AND ENERGY LIMITED, MUMBAI

ITA 3077/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Nov 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 145Section 153C

…After considering the overall facts and circumstances, the assessee's income is considered @ 5% of Rs557001849/- The above estimate gets further vindicated by a judgement of the Honourable Madras Court in the case of CIT vs. Rayala Corporation (P) Ltd. (Mad) 215 ITR 883, wherein the Hon'ble Court adjudicated that best judgement assessment is valid so long as the estimate made by Assessing officer is not arbitrary and has nexus with facts discovered and the same cannot be questioned. It also adjudicated the Assessing Officer is the best judge of the situation. Thus, rejection of books of accounts is justified. Ac…

ACIT CENTRAL CIRCLE 7 (1), MUMBAI vs. LLOYDS METALS AND ENERGY LIMITED, MUMBAI

In the result, for all the

ITA 3076/MUM/2025[2013-14]Status: DisposedITAT Mumbai27 Nov 2025AY 2013-14
Section 143(3)Section 145Section 153C

…er considering the overall facts and circumstances, the\nassessee's income is considered @ 5% of Rs557001849/- The\nabove estimate gets further vindicated by a judgement of the\nHonourable Madras Court in the case of CIT vs. Rayala\nCorporation (P) Ltd. (Mad) 215 ITR 883, wherein the Hon'ble\nCourt adjudicated that best judgement assessment is valid so\nlong as the estimate made by Assessing officer is not arbitrary\nand has nexus with facts discovered and the same cannot be\nquestioned. It also adjudicated the Assessing Officer is the best\njudge of the situation.\n\nThus, rejection of books of accounts is justi…

ACIT CENTRAL CIRCLE 7 (1), MUMBAI vs. LLOYDS METALS AND ENERGY LIMITED, MUMBAI

In the result, for all the

ITA 3075/MUM/2025[2014-15]Status: DisposedITAT Mumbai27 Nov 2025AY 2014-15
Section 143(3)Section 145Section 153C

…er considering the overall facts and circumstances, the\nassessee's income is considered @ 5% of Rs557001849/- The\nabove estimate gets further vindicated by a judgement of the\nHonourable Madras Court in the case of CIT vs. Rayala\nCorporation (P) Ltd. (Mad) 215 ITR 883, wherein the Hon'ble\nCourt adjudicated that best judgement assessment is valid so\nlong as the estimate made by Assessing officer is not arbitrary\nand has nexus with facts discovered and the same cannot be\nquestioned. It also adjudicated the Assessing Officer is the best\njudge of the situation.\n\nThus, rejection of books of accounts is justi…

ACIT CENTRAL CIRCLE 7 (1), MUMBAI vs. LLOYDS ENTERPRISES LIMITED, MUMBAI

In the result, for all the

ITA 3074/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Nov 2025AY 2018-19
Section 143(3)Section 145Section 153C

…er considering the overall facts and circumstances, the\nassessee's income is considered @ 5% of Rs557001849/- The\nabove estimate gets further vindicated by a judgement of the\nHonourable Madras Court in the case of CIT vs. Rayala\nCorporation (P) Ltd. (Mad) 215 ITR 883, wherein the Hon'ble\nCourt adjudicated that best judgement assessment is valid so\nlong as the estimate made by Assessing officer is not arbitrary\nand has nexus with facts discovered and the same cannot be\nquestioned. It also adjudicated the Assessing Officer is the best\njudge of the situation.\n\nThus, rejection of books of accounts is justi…

ACIT CENTRAL CIRCLE 7 (1), MUMBAI vs. LLOYDS ENTERPRISES LIMITED, MUMBAI

In the result, for all the

ITA 3073/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Nov 2025AY 2017-18
Section 143(3)Section 145Section 153C

…er considering the overall facts and circumstances, the\nassessee's income is considered @ 5% of Rs557001849/- The\nabove estimate gets further vindicated by a judgement of the\nHonourable Madras Court in the case of CIT vs. Rayala\nCorporation (P) Ltd. (Mad) 215 ITR 883, wherein the Hon'ble\nCourt adjudicated that best judgement assessment is valid so\nlong as the estimate made by Assessing officer is not arbitrary\nand has nexus with facts discovered and the same cannot be\nquestioned. It also adjudicated the Assessing Officer is the best\njudge of the situation.\nThus, rejection of books of accounts is justifi…

ACIT CENTRAL CIRCLE 7 (1) , MUMBAI vs. LLOYDS ENTERPRISES LIMITED, MUMBAI

In the result, for all the

ITA 3072/MUM/2025[2016-17]Status: DisposedITAT Mumbai27 Nov 2025AY 2016-17
Section 143(3)Section 145Section 153C

…nAfter considering the overall facts and circumstances, the assessee's income is considered @ 5% of Rs557001849/- The above estimate gets further vindicated by a judgement of the Honourable Madras Court in the case of CIT vs. Rayala Corporation (P) Ltd. (Mad) 215 ITR 883, wherein the Hon'ble Court adjudicated that best judgement assessment is valid so long as the estimate made by Assessing officer is not arbitrary and has nexus with facts discovered and the same cannot be questioned. It also adjudicated the Assessing Officer is the best judge of the situation.\n\nThus, rejection of books of accounts is justified.…

ACIT CENTRAL CIRCLE 7 (1), MUMBAI vs. LLOYDS ENTERPRISES LIMITED, MUMBAI

ITA 3070/MUM/2025[2013-14]Status: DisposedITAT Mumbai27 Nov 2025AY 2013-14

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 145Section 153C

…After considering the overall facts and circumstances, the assessee's income is considered @ 5% of Rs557001849/- The above estimate gets further vindicated by a judgement of the Honourable Madras Court in the case of CIT vs. Rayala Corporation (P) Ltd. (Mad) 215 ITR 883, wherein the Hon'ble Court adjudicated that best judgement assessment is valid so long as the estimate made by Assessing officer is not arbitrary and has nexus with facts discovered and the same cannot be questioned. It also adjudicated the Assessing Officer is the best judge of the situation. Thus, rejection of books of accounts is justified. Ac…

LLOYDS ENTERPRISES LIMITED (FORMERLY KNOWN AS SHREE GLOBAL TRADEFIN LIMITED ),MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 7(1), MUMBAI

ITA 2856/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Nov 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 145Section 153C

…After considering the overall facts and circumstances, the assessee's income is considered @ 5% of Rs557001849/- The above estimate gets further vindicated by a judgement of the Honourable Madras Court in the case of CIT vs. Rayala Corporation (P) Ltd. (Mad) 215 ITR 883, wherein the Hon'ble Court adjudicated that best judgement assessment is valid so long as the estimate made by Assessing officer is not arbitrary and has nexus with facts discovered and the same cannot be questioned. It also adjudicated the Assessing Officer is the best judge of the situation. Thus, rejection of books of accounts is justified. Ac…

LLOYDS ENTERPRISES LIMITED (FORMERLY KNOWN AS SHREE GLOBAL TRADEFIN LIMITED ),MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -7(1), MUMBAI

In the result, for all the

ITA 2855/MUM/2025[2013-14]Status: DisposedITAT Mumbai27 Nov 2025AY 2013-14
Section 143(3)Section 145Section 153C

…er considering the overall facts and circumstances, the\nassessee's income is considered @ 5% of Rs557001849/- The\nabove estimate gets further vindicated by a judgement of the\nHonourable Madras Court in the case of CIT vs. Rayala\nCorporation (P) Ltd. (Mad) 215 ITR 883, wherein the Hon'ble\nCourt adjudicated that best judgement assessment is valid so\nlong as the estimate made by Assessing officer is not arbitrary\nand has nexus with facts discovered and the same cannot be\nquestioned. It also adjudicated the Assessing Officer is the best\njudge of the situation.\nThus, rejection of books of accounts is justifi…

LLOYDS METALS AND ENERGY LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -7(1), MUMBAI

ITA 2646/MUM/2025[2019-20]Status: DisposedITAT Mumbai27 Nov 2025AY 2019-20

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 145Section 153C

…After considering the overall facts and circumstances, the assessee's income is considered @ 5% of Rs557001849/- The above estimate gets further vindicated by a judgement of the Honourable Madras Court in the case of CIT vs. Rayala Corporation (P) Ltd. (Mad) 215 ITR 883, wherein the Hon'ble Court adjudicated that best judgement assessment is valid so long as the estimate made by Assessing officer is not arbitrary and has nexus with facts discovered and the same cannot be questioned. It also adjudicated the Assessing Officer is the best judge of the situation. Thus, rejection of books of accounts is justified. Ac…

LLOYDS METALS AND ENERGY LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -7(1), MUMBAI

In the result, for all the

ITA 2645/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Nov 2025AY 2018-19
Section 143(3)Section 145Section 153C

…er considering the overall facts and circumstances, the\nassessee's income is considered @ 5% of Rs557001849/- The\nabove estimate gets further vindicated by a judgement of the\nHonourable Madras Court in the case of CIT vs. Rayala\nCorporation (P) Ltd. (Mad) 215 ITR 883, wherein the Hon'ble\nCourt adjudicated that best judgement assessment is valid so\nlong as the estimate made by Assessing officer is not arbitrary\nand has nexus with facts discovered and the same cannot be\nquestioned. It also adjudicated the Assessing Officer is the best\njudge of the situation.\n\nThus, rejection of books of accounts is justi…

LLOYDS METALS AND ENERGY LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -7(1), MUMBAI

ITA 2644/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Nov 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 145Section 153C

…After considering the overall facts and circumstances, the assessee's income is considered @ 5% of Rs557001849/- The above estimate gets further vindicated by a judgement of the Honourable Madras Court in the case of CIT vs. Rayala Corporation (P) Ltd. (Mad) 215 ITR 883, wherein the Hon'ble Court adjudicated that best judgement assessment is valid so long as the estimate made by Assessing officer is not arbitrary and has nexus with facts discovered and the same cannot be questioned. It also adjudicated the Assessing Officer is the best judge of the situation. Thus, rejection of books of accounts is justified. Ac…

LLOYDS METALS AND ENERGY LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -7(1), MUMBAI

ITA 2643/MUM/2025[2016-17]Status: DisposedITAT Mumbai27 Nov 2025AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 145Section 153C

…After considering the overall facts and circumstances, the assessee's income is considered @ 5% of Rs557001849/- The above estimate gets further vindicated by a judgement of the Honourable Madras Court in the case of CIT vs. Rayala Corporation (P) Ltd. (Mad) 215 ITR 883, wherein the Hon'ble Court adjudicated that best judgement assessment is valid so long as the estimate made by Assessing officer is not arbitrary and has nexus with facts discovered and the same cannot be questioned. It also adjudicated the Assessing Officer is the best judge of the situation. Thus, rejection of books of accounts is justified. Ac…

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CIT v. Rayala Corporation (P) Ltd. (Mad) (215 ITR 883) — Cited in 40 Judgments | BharatTax