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“rejection of books of account”

ICDS & AccountingSection 145(3)Section 145(3)1,303 judgments

The decision most relied on for rejection of books of account is Lalchand Bhagat Ambica Ram v. CIT (37 ITR 288), cited in 570 judgments on BharatTax.

Leading authorities on rejection of books of account

Lalchand Bhagat Ambica Ram v. CIT
37 ITR 288 · 1959 · Supreme Court
570
citing judgments

Where an assessee maintains regular books of account, and these books are not rejected or found defective by the Assessing Officer, any cash deposits or available cash shown in the cash book, if sufficient to cover the transaction, cannot be treated as unexplained income or an addition under sections 68 or 69A.

CIT v. President Industries
258 ITR 654 · 2002 · High Court
471
citing judgments

When books of account are rejected and unaccounted sales or receipts are discovered, the income addition is restricted to the net profit element embedded in these undisclosed transactions, not the entire sale proceeds or receipts, especially if corresponding purchases are not proven to be outside the books.

Kachwala Gems v. JCIT
288 ITR 10 · 2007 · Supreme Court
332
citing judgments

In a best judgment assessment, some guesswork is inherent, but the estimate must be fair and not arbitrary. Books of account can be rejected under Section 145(3) if the assessee fails to substantiate entries or prove the genuineness of transactions, leading to estimation of income.

Sreelekha Banerjee v. CIT
49 ITR 112 · 1963 · Supreme Court
281
citing judgments

An assessee must explain the source of entries in their account books and prove that the sums are not income; the department is not initially required to prove anything. However, the department cannot unreasonably reject a good explanation, thereby converting valid proof into no proof.

Commissioner of Sales Tax v. H.M. Esufali H.M. Abdulali
90 ITR 271 · 1973 · Supreme Court
232
citing judgments

The Supreme Court established principles for best judgment assessments, stating that some guesswork is inevitable but the assessment must be bona fide, rational, and free from bias or capriciousness. An appellate authority cannot substitute its judgment for that of the Assessing Officer unless the AO's assessment is shown to be biased, irrational, vindictive, or capricious, especially when the assessee fails to provide proper accounts or counter-evidence.

N.K. Proteins Ltd. v. DCIT
84 Taxmann.com 195 · 2017 · Supreme Court
204
citing judgments

When purchases are found to be entirely bogus and based on fictitious invoices from non-existent or unconfirmed suppliers, the entire amount of such purchases is liable to be added back as unexplained expenditure, not merely a percentage thereof.

Indwell Constructions v. CIT
232 ITR 776 · 1998 · High Court
188
citing judgments

When an assessee's income is estimated after rejecting their books of account, further additions or disallowances for specific expenses are generally not permissible, as the estimation already accounts for these.

Sargam Cinema v. CIT
328 ITR 513 · 2010 · Supreme Court
172
citing judgments

For an Assessing Officer to make a valid reference to the Departmental Valuation Officer for the estimation of the cost of construction, the books of accounts must first be rejected under Section 145(3) of the Income-tax Act.

Judgments citing rejection of books of account

Manish Kantilal Kapadia, Mumbai vs. ACIT CC 8(2), Mumbai

In the result, all the appeals

ITA 321/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Nov 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: NoneFor Respondent: Mr. Uma Shankar Prasad, CIT-DR

Assessi allowing the assessee's appeal for disapproving the learn Assessing officer's view of rejecting the Books officer's view of rejecting the Books of Accounts and Income of and Income of appellant by invoking the provision of sectior 145 (3) of the income appellant by invoking the provision ... bogus purchases and sales. Invoking section entries in respect of bogus purchases and sales. Invoking section 145(3) of the Act, he rejected the books of account and, treating the e rejected the books of account and, treating the e rejected the books of account and, treating the Manish Kantilal

Manish Kantilal Kapadia, Mumbai vs. ACIT-CC-8(2), Mumbai

In the result, all the appeals for AY 2014-15 are allowed partly for statistical purposes whereas other appeals are dismissed

ITA 320/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Nov 2025AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: NoneFor Respondent: Mr. Uma Shankar Prasad, CIT-DR
Section 132Section 145(3)Section 153ASection 68

Commissioner of income Tax (Appeal) has erred not allowing the assessee's appeal for disapproving the learn Assessing officer's view of rejecting the Books of Accounts and Income of appellant by invoking the provision of sectior 145 (3) of the income tax Act, 1961. 5. The Learned Commissioner ... recorded by the assessee represented accommodation entries in respect of bogus purchases and sales. Invoking section 145(3) of the Act, he rejected the books of account and, treating the assesssee as an entry operator, estimated commission income at 5% of the declared turnover of ₹51,78,40,543/-, resulting

Manish Kantilal Kapadia, Mumbai vs. ACIT CC 8(2), Mumbai

In the result, all the appeals for AY 2014-15 are allowed partly for statistical purposes whereas other appeals are dismissed

ITA 319/MUM/2025[2016-17]Status: DisposedITAT Mumbai26 Nov 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

Section 132Section 142(1)Section 143(2)Section 145Section 145(3)Section 153ASection 68

Commissioner of income Tax (Appeal) has erred not allowing the assessee's appeal for disapproving the learn Assessing officer's view of rejecting the Books of Accounts and Income of appellant by invoking the provision of section 145 (3) of the income tax Act, 1961. 5. The Learned Commissioner ... recorded by the assessee represented accommodation entries in respect of bogus purchases and sales. Invoking section 145(3) of the Act, he rejected the books of account and, treating the assessee as an entry operator, estimated commission income at 5% of the declared turnover of ₹51,78,40,543/-, resulting

Rekha Manish Kapadia, Mumbai vs. ACIT-CC-8(2), Mumbai

In the result, all the appeals for AY 2014-15 are allowed partly

ITA 280/MUM/2025[2015-16]Status: DisposedITAT Mumbai26 Nov 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: NoneFor Respondent: Mr. Uma Shankar Prasad, CIT-DR
Section 132Section 145(3)Section 153ASection 68

Commissioner of income Tax (Appeal) has erred not allowing the assessee's appeal for disapproving the learn Assessing officer's view of rejecting the Books of Accounts and Income of appellant by invoking the provision of sectior 145 (3) of the income tax Act, 1961. 5. The Learned Commissioner ... recorded by the assessee represented accommodation entries in respect of bogus purchases and sales. Invoking section 145(3) of the Act, he rejected the books of account and, treating the Manish Kantilal Kapadia & Rekha Manish Kapadia 5 ITA Nos. 264, 318 to 322/MUM/2025 & ITA Nos. 263, 280 to 284/MUM/2025 assessee

Manish Kantilal Kapadia, Mumbai vs. DCIT CC -8(2), Mumbai

In the result, all the appeals

ITA 264/MUM/2025[2014-15]Status: DisposedITAT Mumbai26 Nov 2025AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: NoneFor Respondent: Mr. Uma Shankar Prasad, CIT-DR

Assessi allowing the assessee's appeal for disapproving the learn Assessing officer's view of rejecting the Books officer's view of rejecting the Books of Accounts and Income of and Income of appellant by invoking the provision of sectior 145 (3) of the income appellant by invoking the provision ... bogus purchases and sales. Invoking section entries in respect of bogus purchases and sales. Invoking section 145(3) of the Act, he rejected the books of account and, treating the e rejected the books of account and, treating the e rejected the books of account and, treating the Manish Kantilal

Abdulrahman Liyakathali, Erode vs. ACIT, Circle-1, Erode

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1617/CHNY/2025[2015-16]Status: DisposedITAT Chennai25 Nov 2025AY 2015-16

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:1617/Chny/2025 'नधा"रण वष" / Assessment Year: 2015-16 Abdulrahman Liyakathali, Acit, No.30/3, Bhavani Main Road, Vs. Circle-1, B.P.Agraharam, Erode. Erode – 638 005. [Pan: Abapl-5028-J] (अपीलाथ)/Appellant) (*+यथ)/Respondent) अपीलाथ) क, ओर से/Appellant By : Shri. N. Arjun Raj, Advocate *+यथ) क, ओर से/Respondent By : Ms. Gouthami Manivasagam, J.C.I.T. सुनवाई क, तार"ख/Date Of Hearing : 01.09.2025 घोषणा क, तार"ख/Date Of Pronouncement : 25.11.2025 आदेश /O R D E R

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Ms. Gouthami Manivasagam, J.C.I.T
Section 142(1)Section 143(2)Section 143(3)Section 145ASection 54B

present a true and correct picture of the assessee’s :-3-: ITA. No:1617/Chny/2025 business affairs. Accordingly, the AO proposed to reject the books of account and estimate the business income. 7. The assessee objected to the proposal of the AO and submitted that the loss declared from business operations ... such goods deteriorating in quality to the extent claimed is negated. 14. On the cumulative strength of the above observations, the AO rejected the books of account of the assessee and concluded that the correct profits could not be deduced therefrom. The AO thereafter proceeded to estimate the income

Income Tax Officer, Ward-1(3), Ludhiana vs. Shree Balaji Processors, Ludhiana

The appeal stands dismissed

ITA 797/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh24 Nov 2025AY 2016-17

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No. 797/Chandi/2023 (िनधा"रण वष" / Assessment Year: 2016-17) Ito Ward 1(3) Shree Balaji Processors बनाम/ Ludhiana – 141001 Tajpur Road, Opp. Central Jail Vs. Ludhiana - 141010 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Actfs-8428-B (अपीलाथ"/Appellant) (""थ" / Respondent) : Assessee By : Shri Sudhir Sehgal (Advocate) - Ld. Ar Revenue By : Shri Bharat Bhushan Garg (Cit) – Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 11-11-2025 घोषणाकीतारीख /Date Of Pronouncement : 24/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Revenue For Assessment Year (Ay) 2016-17 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac, Delhi [Cit(A)] Dated 18-10-2023 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) Of The Act On 23-12-2018 Rejecting Books Of The Assessee & Assessing Business Profit Of Rs.12.81 Crores. The Ld. Cit(A) Reversed The Action Of Ld. Ao Against Which The Revenue Is In Further Appeal Before Us With Following Grounds Of Appeal: - 1. That The Cit(A), Ludhiana Has Erred In Law, In Deleting Addition Of Rs.12,01,85,191/- Made By The Assessing Officer On Account Of Rejecting The Books Of Accounts U/S 145(3) Of The Act.

For Appellant: Shri Sudhir Sehgal (Advocate) - Ld. ARFor Respondent: Shri Bharat Bhushan Garg (CIT) – Ld. DR (Virtual)
Section 142(1)Section 143(3)Section 145(3)

Ludhiana has erred in law, in deleting addition of Rs.12,01,85,191/- made by the Assessing Officer on account of rejecting the books of accounts u/s 145(3) of the Act. 2. That the CIT(A), Ludhiana has erred in law, in not granting opportunity to the Assessing Officer ... addition evidences. 3. That the CIT(A), Ludhiana has erred in law, in rejecting the rational of AO with regard to the rejection of books of accounts of the assessee. The Ld. CIT-DR advanced arguments on violation of rule 46A and pleaded for confirmation of the assessment order

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Southern Agrifurane Industries Private Limited, Chennai

ITA 1819/CHNY/2025[2022-23]Status: DisposedITAT Chennai21 Nov 2025AY 2022-23

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita Nos.1817 To 1819/Chny/2025 निर्धारण वर्ष/Assessment Years: 2020-21 To 2022-23

Section 132Section 139Section 143(2)Section 143(3)Section 153CSection 250

after considering the submissions put forth by the assessee in light of the findings of the AO, had ultimately rejected the books of accounts of the assessee and estimated the profits at 10% of the turnover. Being aggrieved by the order of the Ld. CIT(A), both the assessee ... purchases without GRNs lacked proper documentation, and therefore on these counts sustain the action of the Ld. CIT(A) in rejecting the books of accounts and estimating the profits of the assessee. The relevant findings of Ld.CIT(A) as partly countenanced by us supra, are as under:- "6.2.19 During

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Southern Agrifurane Industries Private Limited, Chennai

ITA 1818/CHNY/2025[2021-22]Status: DisposedITAT Chennai21 Nov 2025AY 2021-22

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita Nos.1817 To 1819/Chny/2025 निर्धारण वर्ष/Assessment Years: 2020-21 To 2022-23 The Dcit, Central Circle-2(2), Chennai. V. M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. (अपीलार्थी/Appellant) [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita Nos.1550 To 1552/Chny/2025 निर्धारणवर्ष/Assessment Years: 2020-21 To 2022-23 M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai – 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख / Date Of Pronouncement : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025 ::2 ::

Section 132Section 139Section 143(2)Section 143(3)Section 153CSection 250

after considering the submissions put forth by the assessee in light of the findings of the AO, had ultimately rejected the books of accounts of the assessee and estimated the profits at 10% of the turnover. Being aggrieved by the order of the Ld. CIT(A), both the assessee ... purchases without GRNs lacked proper documentation, and therefore on these counts sustain the action of the Ld. CIT(A) in rejecting the books of accounts and estimating the profits of the assessee. The relevant findings of Ld.CIT(A) as partly countenanced by us supra, are as under:- "6.2.19 During

Southern Agrifurane Industries Pvt. Ltd., Chennai vs. ACIT, Central Circle-2(2), Chennai

ITA 1552/CHNY/2025[2022-23]Status: DisposedITAT Chennai21 Nov 2025AY 2022-23

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita Nos.1817 To 1819/Chny/2025 निर्धारण वर्ष/Assessment Years: 2020-21 To 2022-23 The Dcit, Central Circle-2(2), Chennai. V. M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. (अपीलार्थी/Appellant) [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita Nos.1550 To 1552/Chny/2025 निर्धारण वर्ष/Assessment Years: 2020-21 To 2022-23 M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai – 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख / Date Of Pronouncement V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025 ::2 ::

Section 132Section 139Section 143(2)Section 143(3)Section 153CSection 250

after considering the submissions put forth by the assessee in light of the findings of the AO, had ultimately rejected the books of accounts of the assessee and estimated the profits at 10% of the turnover. Being aggrieved by the order of the Ld. CIT(A), both the assessee ... purchases without GRNs lacked proper documentation, and therefore on these counts sustain the action of the Ld. CIT(A) in rejecting the books of accounts and estimating the profits of the assessee. The relevant findings of Ld.CIT(A) as partly countenanced by us supra, are as under:- "6.2.19 During

Southern Agrifurane Industries Pvt. Ltd., Chennai vs. ACIT, Central Circle-2(2), Chennai

In the result, both the appeals filed by the Revenue and the

ITA 1551/CHNY/2025[2021-22]Status: DisposedITAT Chennai21 Nov 2025AY 2021-22

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Mrs. C. Yamuna, CIT &
Section 132Section 139Section 143(2)Section 143(3)Section 153CSection 250

after considering the submissions put forth by the assessee in light of the findings of the AO, had ultimately rejected the books of accounts of the assessee and estimated the profits at 10% of the turnover. Being aggrieved by the order of the Ld. CIT(A), both the assessee ... purchases without GRNs lacked proper documentation, and therefore on these counts sustain the action of the Ld. CIT(A) in rejecting the books of accounts and estimating the profits of the assessee. The relevant findings of Ld.CIT(A) as partly countenanced by us supra, are as under:- “6.2.19 During

Southern Agrifurane Industries Pvt. Ltd., Chennai vs. ACIT, Central Circle-2(2), Chennai

ITA 1550/CHNY/2025[2020-21]Status: DisposedITAT Chennai21 Nov 2025AY 2020-21

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita Nos.1817 To 1819/Chny/2025 निर्धारण वर्ष/Assessment Years: 2020-21 To 2022-23 The Dcit, Central Circle-2(2), Chennai. V. M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. (अपीलार्थी/Appellant) [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita Nos.1550 To 1552/Chny/2025 निर्धारणवर्ष/Assessment Years: 2020-21 To 2022-23 M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai – 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख / Date Of Pronouncement V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025 ::2 ::

Section 132Section 139Section 143(2)Section 143(3)Section 153CSection 250

after considering the submissions put forth by the assessee in light of the findings of the AO, had ultimately rejected the books of accounts of the assessee and estimated the profits at 10% of the turnover. Being aggrieved by the order of the Ld. CIT(A), both the assessee ... purchases without GRNs lacked proper documentation, and therefore on these counts sustain the action of the Ld. CIT(A) in rejecting the books of accounts and estimating the profits of the assessee. The relevant findings of Ld.CIT(A) as partly countenanced by us supra, are as under:- "6.2.19 During

Deputy Commissioner of Income Tax, New Delhi vs. Global Agro Corp, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 4544/DEL/2024[2017-18]Status: DisposedITAT Delhi21 Nov 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2017-18] Dcit Vs Global Agro Corp, Room No.1704, Plot No.07,1St Floor, E-2 Block, Central Market West Civic Centre, Avenue Road, New Delhi-110002. West Punjabi Bagh, New Delhi-110026. Pan-Aakfg2650A Appellant Respondent Revenue By Shri Dheeraj Kumar Jaiswal, Sr.Dr Assessee By Shri Nitin Gulati, Ca Date Of Hearing 17.09.2025 Date Of 21.11.2025 Pronouncement Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Revenue Against The Order Dated 19.07.2024 Passed By Ld. Commissioner Of Income Tax (A), [“Ld.Cit(A)”], National Faceless Appeal Centre (“Nfac”), Delhi In Appeal No. Cit(A), Delhi-15/10990/2019-20 U/S 250 Of The Income Tax Act,1961 [“The Act”] Arising Out Of The Assessment Order Dated 31.12.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Is A Partnership Firm, Engaged In Export Of Rice & E-Filed Its Return Of Income On 28.09.2017 Declaring Income At Inr 66,28,650/-. The Case Was Selected Through Cass & After Considering The Submissions Made By The Assessee From Time To Time, Assessment Was Completed U/S 143(3) Vide Assessment Order Dated 31.12.2019 Wherein Following Additions Were Made:

Section 115BSection 143(3)Section 145(3)Section 250Section 40A(2)(b)Section 68

assessee is working on low margin and high turnover. He further submits that merely low G.P rate cannot be the reason for rejecting the books of account and making trading additions more particularly when no specific defect whatsoever was pointed out in the books of account maintained by the assessee ... cash deposited during demonetization in SBN and for this reason he invoked the provisions of section 145(3) of the Act and rejected the books of accounts maintained by the assessee. Besides this, there was no other reason stated for invoking the provision of section

Innovative Telecom and Softwares Private Ltd, Surat vs. Assistant Commissioner of Income Tax, Circle-1(1)(2), Surat

In the result, the appeal of the assessee is allowed

ITA 796/SRT/2023[2017-18]Status: DisposedITAT Surat19 Nov 2025AY 2017-18

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.796/Srt/2023 Assessment Year: (2017-18) (Hybrid Hearing) M/S Innovative Telecom & Vs. Acit, Softwares Pvt. Ltd., Circle – 1(1)(1), O/21-22, Kanaknidhi Apartment, Surat Nanpura, Surat - 395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaci8036R (Appellant) (Respondent) Appellant By Shri Hiren M. Diwan, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 21/08/2025 Date Of Pronouncement 19/11/2025

Section 115BSection 142(1)Section 143(2)Section 144Section 145(3)Section 250Section 68

decision relied upon by the ld. AR. The appellant has not pressed grounds on validity of order u/s 144 of the Act, rejection of books of account u/s 145(3) of the Act. Hence, the only issues for adjudication are addition of Rs.2,25,50,000/- u/s 68 and levy

Sampath Reddy Vem, Warangal vs. ITO., Ward-1, Warangal

In the result, the appeal in ITA No

ITA 1230/HYD/2025[2014-15]Status: DisposedITAT Hyderabad19 Nov 2025AY 2014-15

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1229 & 1230/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2014-15) Shri Sampath Reddy Vem Vs. Income Tax Officer Warangal Ward-1 Pan:Adfpv3598L Warangal (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By:: Shri R. Kumaran, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 12/11/2025 घोषणा की तारीख/Pronouncement: 19/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: Theses Appeals Are Filed By Shri Sampath Reddy Vem (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 23.05.2025 & 24.05.2025 Respectively For The A.Y 2014-15. As Both The Appeals Are Related To The Same Assessee Therefore, For The Purpose Of Convenience & Brevity, These Two Appeals Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Shri K.A. Sai Prasad, CAFor Respondent: : Shri R. Kumaran, Sr. DR
Section 143(3)Section 44A

inaccurate particulars. 4. The Learned CIT(A), NFAC erred in not appreciating that where income is assessed on estimated basis, especially after rejection of books of account, penalty under section 271(1)(c) is not leviable, as held by various judicial pronouncements, including that of the Hon'ble Supreme Court

Sampath Reddy Vem, Warangal vs. ITO., Ward - 1, Warangal

In the result, the appeal in ITA No

ITA 1229/HYD/2025[2014-15]Status: DisposedITAT Hyderabad19 Nov 2025AY 2014-15

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1229 & 1230/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2014-15) Shri Sampath Reddy Vem Vs. Income Tax Officer Warangal Ward-1 Pan:Adfpv3598L Warangal (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By:: Shri R. Kumaran, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 12/11/2025 घोषणा की तारीख/Pronouncement: 19/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: Theses Appeals Are Filed By Shri Sampath Reddy Vem (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 23.05.2025 & 24.05.2025 Respectively For The A.Y 2014-15. As Both The Appeals Are Related To The Same Assessee Therefore, For The Purpose Of Convenience & Brevity, These Two Appeals Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Shri K.A. Sai Prasad, CAFor Respondent: : Shri R. Kumaran, Sr. DR
Section 143(3)Section 44A

inaccurate particulars. 4. The Learned CIT(A), NFAC erred in not appreciating that where income is assessed on estimated basis, especially after rejection of books of account, penalty under section 271(1)(c) is not leviable, as held by various judicial pronouncements, including that of the Hon'ble Supreme Court

Avanti Parshav Multiventure Private Ltd, Mumbai vs. DCIT Central Circle 5(2), Mumbai

ITA 5205/MUM/2025[2022-23]Status: DisposedITAT Mumbai19 Nov 2025AY 2022-23

Bench: Shri Pawan Singh& Ms. Padmavathy S

Section 148Section 254(1)

same. 6. On the facts and circumstances of the case and in law, the Ld. 6 CT(A) erred in confirming the rejection of books of accounts u/s 145(3) of the Income Tax Act, 1961. 7. On the facts and circumstances of the case ... that Lokesh Khabya Group was providing accommodation entry of sales, purchase and loans on accepting commission for providing such entries. Assessing officer rejected the books of account and estimated addition on account of income as entry operator. The assessing officer made addition on account of commission on sale and purchase

Avanti Parshav Multiventure Private Ltd, Mumbai vs. DCIT Central Circle 5(2), Mumbai

ITA 5204/MUM/2025[2021-22]Status: DisposedITAT Mumbai19 Nov 2025AY 2021-22

Bench: Shri Pawan Singh& Ms. Padmavathy S

Section 148Section 254(1)

same. 6. On the facts and circumstances of the case and in law, the Ld. 6 CT(A) erred in confirming the rejection of books of accounts u/s 145(3) of the Income Tax Act, 1961. 7. On the facts and circumstances of the case ... that Lokesh Khabya Group was providing accommodation entry of sales, purchase and loans on accepting commission for providing such entries. Assessing officer rejected the books of account and estimated addition on account of income as entry operator. The assessing officer made addition on account of commission on sale and purchase

Avanti Parshav Multiventure Private Ltd, Mumbai vs. DCIT Central Circle 5(2), Mumbai

ITA 5203/MUM/2025[2020-21]Status: DisposedITAT Mumbai19 Nov 2025AY 2020-21

Bench: Shri Pawan Singh& Ms. Padmavathy S

Section 148Section 254(1)

same. 6. On the facts and circumstances of the case and in law, the Ld. 6 CT(A) erred in confirming the rejection of books of accounts u/s 145(3) of the Income Tax Act, 1961. 7. On the facts and circumstances of the case ... that Lokesh Khabya Group was providing accommodation entry of sales, purchase and loans on accepting commission for providing such entries. Assessing officer rejected the books of account and estimated addition on account of income as entry operator. The assessing officer made addition on account of commission on sale and purchase

Sourabh Sethi, Mumbai vs. DCIT Central Circle 5(2), Mumbai

ITA 5201/MUM/2025[2023-24]Status: DisposedITAT Mumbai19 Nov 2025AY 2023-24

Bench: Shri Pawan Singh& Ms. Padmavathy S

Section 148Section 254(1)

same. 6. On the facts and circumstances of the case and in law, the Ld. 6 CT(A) erred in confirming the rejection of books of accounts u/s 145(3) of the Income Tax Act, 1961. 7. On the facts and circumstances of the case ... that Lokesh Khabya Group was providing accommodation entry of sales, purchase and loans on accepting commission for providing such entries. Assessing officer rejected the books of account and estimated addition on account of income as entry operator. The assessing officer made addition on account of commission on sale and purchase