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“estimation of income”

Assessment ProceduresSection 145Section 1453,061 judgments

The decision most relied on for estimation of income is CIT v. Simit P. Sheth (356 ITR 451), cited in 1,465 judgments on BharatTax.

Leading authorities on estimation of income

CIT v. Simit P. Sheth
356 ITR 451 · 2013 · High Court
1,465
citing judgments

When purchases are unproved or presumed to be from the grey market, the entire amount of such purchases should not be disallowed; instead, income can be estimated by applying a reasonable gross profit rate to the unaccounted sales or turnover, especially in assessments arising from search proceedings involving seized documents.

Rotork Controls India Pvt. Ltd. v. CIT
314 ITR 62 · 2009 · Supreme Court
739
citing judgments

A provision for expenses, such as warranty, is a deductible liability for income tax purposes if it constitutes a present obligation arising from past events, and a reliable estimate of the amount of obligation is possible.

Sanjay Oilcake Industries v. CIT
316 ITR 274 · 2009 · High Court
460
citing judgments

In cases of alleged bogus or unverifiable purchases, rather than disallowing the entire purchase value, a reasonable profit element or a proportionate percentage of the purchases should be added back to the assessee's income.

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.

CIT v. Devi Prasad Vishwanath Prasad
72 ITR 194 · 1969 · Supreme Court
272
citing judgments

If there is an unexplained cash credit, the Assessing Officer can treat it as the assessee's income, even when the income is finalized on an estimation basis, without proving its specific source. The onus then shifts to the assessee to prove that the income represented by the cash credit has already been taxed.

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.

CIT v. Balchand Ajit Kumar
263 ITR 610 · 2003 · High Court
212
citing judgments

When making an addition for unaccounted receipts, on-money, or non-genuine purchases/sales, the addition should be restricted to the estimated profit element embedded in such transactions, rather than the entire gross amount, particularly when evidence of corresponding expenditure is incomplete. This estimation often involves applying a net profit rate.

Harigopal Singh v. CIT
258 ITR 85 · 2002 · High Court
203
citing judgments

Penalty under section 271(1)(c) cannot be levied when an addition to income is made on an estimated basis without concrete evidence of concealment or furnishing inaccurate particulars of income. The provisions of section 271(1)(c) are not attracted to cases where income is assessed on an estimate basis.

Judgments citing estimation of income

Rajni Gupta, New Delhi vs. ACIT, New Delhi

In the result, appeals filed by the assessee are partly allowed

ITA 2949/DEL/2017[2005-06]Status: DisposedITAT Delhi20 Jan 2020AY 2005-06

Bench: Shri H.S. Sidhu & Shri Anadee Nath Misshra

For Appellant: Shri S.B. Gupta, CAFor Respondent: Smt. Sushma Singh, CIT(DR)
Section 234A

short). Vide separate impugned appellate orders, each dated 03.11.2015, the Ld. CIT(A) partly allowed the aforesaid appeals and estimated the income of the assessee at Rs. 2,25,000/- for Assessment Year 2005-06; Rs. 2,50,000/- for Assessment Year 2006-07; Rs. 2,75,000/- for Assessment ... time of hearing before us, the Ld. Authorized Representative (“Ld. AR”, for short) of the assessee submitted that the estimation of income made by the Ld. CIT(A) was on the higher side, and made a prayer that the AO be directed to assess the income of the assessee

ITO 29 (2)(4), Mumbai vs. Navin Jaidhand Doshi, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 6418/MUM/2018[2009-10]Status: DisposedITAT Mumbai15 Jan 2020AY 2009-10

Bench: Shri Mahavir Singh & Shri G. Manjunathaito-29(2)(4) Vs. Shri. Navin Jaichand Doshi Building No. C-10 D-705, Kalp Nagri 2Nd Floor, Room No.205, Balrajeshwar Road Pratyakshakar Bhawan Mulund West Bkc , Bandra(East) Mumbai-400 080 Mumbai-400 051 Pan/Gir No.Addpd0288P (Appellant) .. Respondent)

Section 143(3)Section 147Section 69C

scaled down addition to 12.5% gross profit on total alleged bogus purchase. Although, both authorities have taken different rate of profit for estimation of income from alleged bogus purchase, but no one could support said rate of gross profit with necessary evidences or any comparable cases. Therefore, considering facts

ITO, Ward- 17 (1)(3), Mumbai vs. Boon Petrochem House, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 6403/MUM/2018[2011-12]Status: DisposedITAT Mumbai15 Jan 2020AY 2011-12

Bench: Shri Mahavir Singh & Shri G. Manjunathaito-17(1)(3) Vs. Boon Petrochem House Room No.135, 1St Floor, 53/55, Bhandari Street Aaykar Bhawan Masjid Bunder M.K.Road Mumbai-400 003 Mumbai-400 020 Pan/Gir No.Aaafb7130J (Appellant) .. Respondent)

Section 133(6)Section 143(3)Section 147

scaled down addition to 8% gross profit on total alleged bogus purchase. Although, both authorities have taken different rate of profit for estimation of income from alleged bogus purchase, but no one could support said rate of gross profit with necessary evidences or any 6 Boon Petrochem House comparable cases

The ACIT, Circle-1, Bhavnagar vs. Shri Chhotubha Shivubha Sarvaiya, Bhavnagar

In the result, this ground of assessee is partly allowed

ITA 2920/AHD/2014[2010-11]Status: DisposedITAT Ahmedabad14 Jan 2020AY 2010-11

Bench: Shri Mahavir Prasad & Shri Amarjit Singh)

For Appellant: Shri Alok Singh,CIT/DRFor Respondent: Shri Tushar Hemani, P.B. Parmar

turnover of the appellant greater than the monetary limits but certainly those provisions applies having the similar nature of business whereby the estimation of income has been prescribed @ 8% of the total turnover/gross receipts. 4.37. In this regard reliance is also placed on the decision of Hon'ble Mumbai ITAT ... case of assessee being a civil contractor with presumptive statutory rate as prescribed under section 44AD provide a good guideline for purpose of estimation of income. 4.38. In this regard, reliance has been placed in the case of K. Kannan Vs. ACIT, Cir.l Tax Appeals No.679

Annapurna Marketing Co., Rourkela vs. ITO, Ward-2, Rourkela

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

ITA 353/CTK/2019[2010-11]Status: DisposedITAT Cuttack10 Jan 2020AY 2010-11

Bench: Shri Before Shri Chandra Mohan Garg, Judicialassessment Year : 2010-11 Annapurna Marketing Co. Marketing Co. Vs. Ito, Ward-2, Rourkela 2, Rourkela Basanti Basanti Colony Colony Road, Road, Udit Udit Nagar, Rourkela. Nagar, Rourkela. Pan/Gir No. No.Aarfa 0259 L (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : None Revenue By : Shri J.K.Lenka , Dr Date Of Hearing : 10/01/ 20 / 2020 Date Of Pronouncement : 10/01 01/2020 O R D E R

For Appellant: NoneFor Respondent: Shri J.K.Lenka
Section 143(3)Section 144Section 250(6)Section 251

grounds: “ 1.That, Ld. Commissioner of Income Tax 1.That, Ld. Commissioner of Income Tax (Appeals) is wrong in (Appeals) is wrong in confirming the estimation of income by the Ld. Assessing Officer in confirming the estimation of income by the Ld. Assessing Officer in confirming the estimation of income ... fact that the assessment order passed u/s 143(3) and view of the fact that the assessment order passed u/s 143(3) and estimation of income is permissible u/s 144 only, not u/s 143(3), estimation of income is permissible u/s 144 only, not u/s 143(3), estimation of income

Pushpa Devi Rathi, Hyderabad vs. Income Tax Officer, Ward-9(4), Hyderabad

In the result, assessee’s appeal is treated as allowed for statistical purposes

ITA 1141/HYD/2019[2016-17]Status: DisposedITAT Hyderabad08 Jan 2020AY 2016-17

Bench: Smt. P. Madhavi Deviassessment Year: 2016-17

For Appellant: Sri S. Rama RaoFor Respondent: Sri Anil Sant, DR
Section 143(2)Section 234DSection 68

Rs.5,94,641/- made by the AO u/s 68 of the I.T. Act. 3. The learned CIT (A) erred in confirming the estimation of income at 3% of the turnover. 4. The learned CIT (A) erred in confirming levy of interest u/s 234D of Rs.15,744/-. 5. Any other ground

M/S Pradeep Kumar Contractor, Jhunjhunu vs. Assistant Commissioner of Income Tax, Jhunjhunu

In the result, the appeal of the assessee is dismissed

ITA 374/JPR/2018[2014-15]Status: DisposedITAT Jaipur08 Jan 2020AY 2014-15

Bench: : Shri Vijay Pal Rao, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 374/Jp/2018 Fu/Kzkj.K O"Kz@Assessment Year : 2014-15 Cuke Shri Pradeep Kumar Contractor The Acit Vs. Morolia Mension, Station Road Circle- Jhunjhunu Jhunjhunu Jhunjhunu Lfkk;H Ys[Kk La-@Thvkbzvkj La-@ Pan/Gir No.: Aagfp 9445 C Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Manish Agarwal, Ca Jktlo Dh Vksj Ls@ Revenue By : Shri K.C. Gupta, Jcit-Dr Lquokbz Dh Rkjh[K@ Date Of Hearing : 02/12/2019 ?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 09 /01/2020 Vkns'K@ Order Per Vijay Pal Rao, Jm This Appeal By The Assessee Is Directed Against The Order Of Ld. Cit(A)-3, Jaipur Dated 07-02-2018 For The Assessment Year 2014-15. The Assessee Has Raised The Following Grounds. ‘’1. On The Facts & In The Circumstances Of The Case The Ld. Cit(A) Has Grossly Erred In Confirming The Action Of Ao In Invoking The Provisions Of Section 145(3) & Thereby Rejecting Books Of Accounts. Appellant Prays

For Appellant: Shri Manish Agarwal, CAFor Respondent: Shri K.C. Gupta, JCIT-DR
Section 145(3)

frame the assessment based on best judgement u/s 145(3) r.w.s. 144 of the Act. It is a settled principle of law that estimation of income after rejection of books of account should be based on proper and reasonable criteria and past history of the g.p. declared by the assessee ... reasonable guidance for estimation of income. In the case in hand, there is no dispute that assessee has declared the g.p. at 14.04% in comparison to the g.p. rate for A.Y. 2012-13 at 18.63% and for A.Y. 2013-14 at 18.15%. Therefore, the average of preceding two years

ITO - 27 (1)(4), Mumbai vs. Chandrakant M. Gada, Mumbai

ITA 6316/MUM/2018[2009-10]Status: DisposedITAT Mumbai08 Jan 2020AY 2009-10

Bench: Shri Saktijit Dey, Jm & Shri S. Rifaur Rahman, Am आयकरअपीलसं./ I.T.A. No. 6316/Mum/2018 (निर्धारणवर्ा / Assessment Year: 2009-10)

For Appellant: Shri Kumar PadmapaniFor Respondent: Shri Dilip V. Nathani, AR

merit, the penalty was levied on estimation of disallowance on bogus purchase. The courts have held that penalty cannot be levied on estimation of income. 6. In the net result, the appeal filed by the revenue stands dismissed. Order pronounced in the open court on 8th Jan, 2020. (Saktijit

Niranjan Jata, Bhubaneswar vs. DCIT, Salary Circle-3(1), Bhubaneswar

In the result, appeal of the assessee is allowed

ITA 185/CTK/2019[2016-17]Status: DisposedITAT Cuttack31 Dec 2019AY 2016-17

Bench: Shri Chandra Mohan Gargassessment Year : 2016-17

For Appellant: Shri P.R.Mohanty, ARFor Respondent: Shri Subhendu Dutta, DR
Section 28Section 43CSection 44ASection 71

been passed on improper application of mind, being devoid of merit as such deserves to be quashed in limine. 2. For that, the estimation of income of trading transaction in derivatives U/s 44AD without accepting the returned loss, converting a loss into estimated profit not only is unjustified

DCIT, Circle - 10(1), Kolkata vs. M/S. Anjan Infrastructures Pvt. Ltd., Kolkata

In the result, revenue appeal is allowed for statistical purposes

ITA 878/KOL/2018[2013-14]Status: DisposedITAT Kolkata31 Dec 2019AY 2013-14

Bench: "ी जे. सुधाकर रे"डी, लेखा सद"य एवं/And "ी ऐ. ट". वक", "यायीक सद"य) [Before Shri J. Sudhakar Reddy, Am & Shri A. T. Varkey, Jm]

Section 139(1)Section 41(1)

case of Samurai Techno Trading corporation Ltd. vs. CIT (2010) 37 DTR 386, Kerala High court, the Kerala High court held that in estimation of income in the case of building contractors a percentage of 8 per cent can be adopted even where the turnover exceeds 40 lakhs ... assessment order on 19.02.2016] and added to the income of the assessee. On appeal, the Ld. CIT(A) deleted the addition by estimating the income after rejecting the books of account which action cannot be countenanced. We note that the Ld. CIT(A) has no where given a finding that

Srinivas Narla, Siddipet vs. Income Tax Officer, Ward-1, Siddipet

In the result, assessee’s appeal is partly allowed

ITA 424/HYD/2019[2013-14]Status: DisposedITAT Hyderabad30 Dec 2019AY 2013-14

Bench: Smt. P. Madhavi Devish. Srinivas Narla Vs Income Tax Officer Prop:Chamundeswari Wines Ward 1 Siddipet Siddipet Pan: Aezpn8544F (Appellant) (Respondent) For Assessee : Shri T. Chaitanya Kumar, Ar For Revenue : Shri Nilanjan Dey, Dr Date Of Hearing: 30.12.2019 Date Of Pronouncement: 30.12.2019 O R D E R This Is Assessee’S Appeal For The A.Y 2013-14 Against The Order Of The Cit (A)-7, Hyderabad, Dated 12.01.2018. 2. Initially The Tribunal Had Raised An Objection That The Appeal Is Barred By Limitation As There Is A Delay Of 319 Days In Filing Of The Appeal. However, Ld.Dr Has Filed The Report Of The Cit(A)-7, Hyderabad Stating That The Copy Of The Order Of The Cit(A) Was Returned Unserved To Their Office & That The Assessee Was Served With The Appellate Order On 16.02.2019. Taking The Same Into Consideration, I Hold That There Is No Delay In Filing The Appeal Before The Tribunal. 3. The Assessee Has Raised The Following Grounds Of Appeal: “ 1. The Order Of The Cit (A) Is Erroneous Both On Facts & In Law. 2. The Learned Cit (A) Erred In Confirming The Order Of The Assessing Officer In Rejecting Books Of Accounts U/S 145 Of The Act & Further Erred In Estimating The Income @ 5% On Liquor Sales. 3. The Learned Cit (A) Ought To Have Observed That The Appellant Not Derived Income As Per Targeted Sales. 4. The Learned Cit (A) Erred In Confirming The Order Of The Assessing Officer In Estimating The Income @ 5% On Cost Of Sales.

For Appellant: Shri T. Chaitanya Kumar, ARFor Respondent: Shri Nilanjan Dey, DR
Section 145

erred in confirming the order of the Assessing Officer in rejecting books of accounts u/s 145 of the Act and further erred in estimating the income @ 5% on liquor sales. 3. The learned CIT (A) ought to have observed that the appellant not derived income as per targeted sales ... learned CIT (A) erred in confirming the order of the Assessing Officer in estimating the income @ 5% on cost of sales. ITA No.424/Hyd./2019 A.Y.: 2013-14 Sri Srinivas Narla, Siddipet 5. The order of the learned CIT (A) in confirming the action of the AO in determining the total

Infrastructure Leasing & Financial Services Ltd, Mumbai vs. DCIT 10(1), Mumbai

In the result, appeals of the assessee as well as revenue are partly allowed as indicated above

ITA 7092/MUM/2014[2010-11]Status: DisposedITAT Mumbai30 Dec 2019AY 2010-11

Bench: Shri C.N. Prasad, Hon'Ble & Shri G. Manjunatha, Hon'Ble

For Appellant: Shri Sandeep BhallaFor Respondent: Shri Awangshi Gimson
Section 10

have not received any interest income from MPSIDC and hence the direction of the Learned Commr. of Income Tax (Appeals) to tax the estimated interest income may be set aside. 5. The Learned A.O. has erred in disallowing the sum of Rs 6.28 crores being the administrative / establishment expenses attributable ... perused materials available on record and gone through the orders of authorities below. The issue of depreciation on toll road as well as estimation of income from such road is subject matter of consideration by the Tribunal for AY 2004-05. The Tribunal after considering rival submissions of the assessee

Infrastructure Leasing & Financial Services Ltd, Mumbai vs. DCIT 10(1), Mumbai

In the result, appeals of the assessee as well as revenue are partly allowed as indicated above

ITA 7091/MUM/2014[2011-12]Status: DisposedITAT Mumbai30 Dec 2019AY 2011-12

Bench: Shri C.N. Prasad, Hon'Ble & Shri G. Manjunatha, Hon'Ble

For Appellant: Shri Sandeep BhallaFor Respondent: Shri Awangshi Gimson
Section 10

have not received any interest income from MPSIDC and hence the direction of the Learned Commr. of Income Tax (Appeals) to tax the estimated interest income may be set aside. 5. The Learned A.O. has erred in disallowing the sum of Rs 6.28 crores being the administrative / establishment expenses attributable ... perused materials available on record and gone through the orders of authorities below. The issue of depreciation on toll road as well as estimation of income from such road is subject matter of consideration by the Tribunal for AY 2004-05. The Tribunal after considering rival submissions of the assessee

DCIT 10(1), Mumbai vs. Infrastructure Leasing & Financial Services Ltd, Mumbai

In the result, appeals of the assessee as well as revenue are partly allowed as indicated above

ITA 6829/MUM/2014[2011-12]Status: DisposedITAT Mumbai30 Dec 2019AY 2011-12

Bench: Shri C.N. Prasad, Hon'Ble & Shri G. Manjunatha, Hon'Ble

For Appellant: Shri Sandeep BhallaFor Respondent: Shri Awangshi Gimson
Section 10

have not received any interest income from MPSIDC and hence the direction of the Learned Commr. of Income Tax (Appeals) to tax the estimated interest income may be set aside. 5. The Learned A.O. has erred in disallowing the sum of Rs 6.28 crores being the administrative / establishment expenses attributable ... perused materials available on record and gone through the orders of authorities below. The issue of depreciation on toll road as well as estimation of income from such road is subject matter of consideration by the Tribunal for AY 2004-05. The Tribunal after considering rival submissions of the assessee

I.T.O.19(3)(1), Mumbai vs. Ramesh B. Doshi, Mumbai

In the result, appeal of the assessee is allowed

ITA 5436/MUM/2018[2003-04]Status: DisposedITAT Mumbai23 Dec 2019AY 2003-04

Bench: Shri R.C. Sharmaआमकय अऩीर सं./I.T.A. No. 5436/Mum/2018 (निर्धारण वषा / Assessment Years : 2003-04) बिधम/ Ito 19(3)(1) Ramesh B. Doshi R.No. 202, 2Nd Floor, Mtru A-1, Maniyar Bldg., Vs. Flat No. 34, 3Rd Floor, Mandir, Tardeo, Road, Mumbai. Near Film Centre, Tardeo, Mumbai. स्थामी रेखा सं./जीआइआय सं./ Pan/Gir No. : Aadpd3476E (प्रत्मथी / Respondent) (अऩीराथी /Appellant) .. अऩीराथी ओय से / Appellant By : Shri R. Bhoopathy, Dr प्रत्मथी की ओय से/Respondent By : Shri Rajkumar Singh, Ar सुनवाई की तायीख / Date Of Hearing 20/12/2019 घोषणा की तायीख /Date Of Pronouncement 23 /12 /2019

For Appellant: Shri R. Bhoopathy, DRFor Respondent: Shri Rajkumar Singh, AR
Section 143(3)Section 271Section 271(1)(c)Section 274

penalty was not leviable. CIT(A) deleted the penalty by ITA No. 5436//Mum/2018. Ramesh B. Doshi, Mumbai. observing that addition made on estimation of income does not attract penalty u/s.271(1)(c). Precise observation of the CIT(A) is as under: I have considered the facts of the case ... before Hon'ble ITAT decided the case. The Appellant also contended against the penalty stating that the penalty has been levied on estimated commission income which has further been reduced by Hon'ble Tribunal. I found force in the assessee's submissions. I have gone through the assessment order, penalty

Kothakota Sri Ramulu, Vizianagaram vs. The Income Tax Officer, Ward-2, Vizianagaram

In the result, appeals of the assessee is partly allowed

ITA 611/VIZ/2018[2010-11]Status: DisposedITAT Visakhapatnam18 Dec 2019AY 2010-11

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.611/Viz/2018 (ननधधारण वर्ा/Assessment Year : 2010-11) Kothakota Sri Ramulu Vs. Income Tax Officer D.No.17-9 Ward-2 Ch.Agraharam Vizianagaram Poosapatirega Vizianagaram [Pan :Akfpk9259E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Shri B.Rama Krishna, DR
Section 44A

Assessment Year (A.Y.) 2010-11. 2 I.T.A. No.611/Viz/2018, A.Y.2010-11 Kothakota Sri Ramulu, VSisakhapatnam 2. All the grounds of appeal are related to the estimation of income. The assessee is a labour supply contractor and for the A.Y.2010-11, the assessee filed the return of income electronically on 11.10.2010 admitting total income ... expenditure, hence viewed that true and correct profits cannot be deduced from the books of accounts. Accordingly rejected the books of accounts and estimated the income @10% of the gross receipts. 3. Against the order of the AO, the assessee went on appeal before the CIT(A) and the Ld.CIT

G J Trading Private Limited, Hyderabad vs. Dy, Commissioner of Income Tax, Circle-2(3), Hyderabad

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

ITA 1610/HYD/2017[2006-07]Status: DisposedITAT Hyderabad17 Dec 2019AY 2006-07

Bench: Smt. P. Madhavi Deviassessment Year: 2006-07 Gj Trading Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Circle – 2(3), Hyderabad. Pan – Aaacg7620H Appellant Respondent Assessee By: Shri P. Murali Mohana Rao Revenue By: Smt. Esther N. Hanghal Date Of Hearing: 17/12/2019 Date Of Pronouncement: 17/12/2019 O R D E R

For Appellant: Shri P. Murali Mohana RaoFor Respondent: Smt. Esther N. Hanghal
Section 143(3)Section 144Section 43(5)

appellant either in earlier assessment years or in subsequent assessment years. 8. The Ld. CIT (A) ought to appreciate that no estimation of income can be done without rejecting books of accounts. 9. The Ld, CIT (A) erred in appreciating the fact that, mere fall in the Gross Profit Ratio ... erred in upholding that Book results as per the Statement of Profit & Loss shall be considered for computation of total income and thus estimation of income done on ad-hoc basis is unsustainable. 13. The Ld. CIT(A) ought to have appreciated that the books of accounts are prepared

DCIT, Central Circle-2(1), Hyd, Hyderabad vs. Annapurna Business Solutions, Hyd, Hyderabad

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

ITA 869/HYD/2015[2010-11]Status: DisposedITAT Hyderabad17 Dec 2019AY 2010-11

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR
Section 10ASection 132

concern to claim such deduction. In fact the AO taxed the entire income claimed as deduction u/s 10A and the Ld.CIT(A) blindly estimated the income without bringing any arrangement or the defects in the books of accounts of the assessee. The Ld.AR further submitted that even it is presumed ... without 49 I.T.A. Nos.831/H/2015 to 836/H/2015 and 298/Viz/2016 I.T.A.Nos.864/H/2015 to 869/H/2015 and 334/Viz/2016. M/s Annapurna Business Solutions, Hyderabad computing the income or estimating the income, there is no reason to disbelieve the income earned by the assessee from the export activity. From the above, it is clear that

DCIT, Central Circle-2(1), Hyd, Hyderabad vs. Annapurna Business Solutions, Hyd, Hyderabad

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

ITA 868/HYD/2015[2009-10]Status: DisposedITAT Hyderabad17 Dec 2019AY 2009-10

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR
Section 10ASection 132

concern to claim such deduction. In fact the AO taxed the entire income claimed as deduction u/s 10A and the Ld.CIT(A) blindly estimated the income without bringing any arrangement or the defects in the books of accounts of the assessee. The Ld.AR further submitted that even it is presumed ... without 49 I.T.A. Nos.831/H/2015 to 836/H/2015 and 298/Viz/2016 I.T.A.Nos.864/H/2015 to 869/H/2015 and 334/Viz/2016. M/s Annapurna Business Solutions, Hyderabad computing the income or estimating the income, there is no reason to disbelieve the income earned by the assessee from the export activity. From the above, it is clear that

DCIT, Central Circle-2(1), Hyd, Hyderabad vs. Annapurna Business Solutions, Hyd, Hyderabad

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

ITA 867/HYD/2015[2008-09]Status: DisposedITAT Hyderabad17 Dec 2019AY 2008-09

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR
Section 10ASection 132

concern to claim such deduction. In fact the AO taxed the entire income claimed as deduction u/s 10A and the Ld.CIT(A) blindly estimated the income without bringing any arrangement or the defects in the books of accounts of the assessee. The Ld.AR further submitted that even it is presumed ... without 49 I.T.A. Nos.831/H/2015 to 836/H/2015 and 298/Viz/2016 I.T.A.Nos.864/H/2015 to 869/H/2015 and 334/Viz/2016. M/s Annapurna Business Solutions, Hyderabad computing the income or estimating the income, there is no reason to disbelieve the income earned by the assessee from the export activity. From the above, it is clear that