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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

Lloyds Metals and Energy Limited, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle, 7(1), Mumbai

ITA 2640/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

very validity of the assumption of jurisdiction under section 153C and, on merits, to the addition sustained by the learned CIT(A) by estimating additional income at zero point five percent of the alleged bogus sales. It is the assessees’ case that even such estimation is unwarranted on the facts ... books of account as not reflecting a true and fair picture of the assessees’ business, financial position and performance, and proceeded to estimate additional income. At this juncture, in the original assessment order, the Assessing Officer reproduced, at great length, his detailed reasoning, the various deficiencies noticed, the statutory provisions

Mediboyana Venkata Appala Surya Prakash, Visakhapatnam vs. Assistant Commissioner of Income Tax, Circle-4(1), Visakhapatnam

ITA 506/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam26 Nov 2025AY 2015-16

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.506/Viz/2025 (िनधा"रण वष"/Assessment Year:2015-16) Mediboyana Venkata Appala Vs. Assistant Commissioner Surya Prakash, Of Income Tax, Visakhapatnam. Circle-4(1), Pan: Agnpm7780L Visakhapatnam. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 19/11/2025 Hearing: घोषणा की तारीख/Date Of 26/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 17/06/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 31/10/2017. The 2 Mediboyana Venkata Appala Surya Prakash Vs. Acit

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(1)Section 143(2)Section 143(3)

holding a firm conviction that the books of accounts produced by the assessee suffered from multiple discrepancies rejected the same. Thereafter, the AO estimated the income of the assessee @ 12% of his total receipts of Rs.9,30,07,988/- and computed his income at Rs.1,11,60,959/-. Therefore ... Large other expenses claimed in the Profit & Loss A/c”, but the AO by rejecting the books of accounts of the assessee and estimating his income had traversed beyond the scope of the limited jurisdiction that was vested with him, for verifying the issue for which the case of the assessee

Raghunath Singh, Hyderabad vs. ITO., Ward-7(2), Hyderabad

In the result, the appeal filed by the assessee is allowed for\nstatistical purposes

ITA 490/HYD/2025[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18
Section 143(3)Section 234BSection 69A

receipts of the appellant.\n5. The learned Commissioner of Income Tax (Appeals) erred in confirming\nthe addition made of Rs.34,99,217/- towards estimation of income at 8% of\nthe turnover. The commissioner of Income Tax (Appeals) ought to have\nseen the proper books of account were maintained and, therefore

Manavadariya Dharmendra Kantilal, Hyderabad vs. ITO, Ward-7(1), Hyderabad

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 318/HYD/2025[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

Bench: Us:

Section 143(3)Section 234BSection 69A

appellant. 5. The learned Commissioner of Income Tax (Appeals) erred in confirming the addition made of Rs. 34,99,217/- towards estimation of income at 8% of the turnover. The commissioner of Income Tax (Appeals) ought to have seen the proper books of account were maintained and, therefore, the books

Vedkiran Infra Projects Private Limited, Hyderabad vs. DCIT, Circle-8(1), Hyderabad

In the result, the appeal of the assessee company is allowed in terms of our aforesaid observations

ITA 1556/HYD/2025[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No. 1556/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Vedkiran Infra Projects Vs. Deputy Commissioner Private Limited, Of Income Tax, Hyderabad. Circle-8(1), Pan: Aaecv4030C Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri C. Maheshwar Reddy, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 18/11/2025 घोषणा की तारीख/Date Of 26/11/2025 Pronouncement: आदेश / Order Per Ravish Sood, Jm: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals) [For Short, “Cit(A)”) Dated 10.02.2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 143(3) Of The Income-Tax Act, 1961 (For Short, “Act”) Dated 30.12.2019 For Ay 2017-18. The Assessee Company Has Assailed The Impugned Order Passed By The Cit(A) On The Following Grounds Of Appeal Before Us:

For Appellant: Shri C. Maheshwar ReddyFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 143(3)

liable for deletion. 3. The Ld. CIT(A) has upheld the order of the Ld. AO who estimated the income at a very higher rate of 12.5% by merely comparing with the general nature of industry which is not justifiable, hence the addition made shall be deleted ... industry comparison, which is not sustainable. 6. The Ld. CIT(A) ought to have observed that there is no base for making estimation of income at a higher rate of 12.5% and just by merely citing reference to various other entities, without displaying the comparisons numerically

S N Thakkar Infrastructure Private Limited, Mumbai vs. Circle 14(1)(2), Mumbai

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

ITA 4588/MUM/2025[2018 - 19]Status: DisposedITAT Mumbai26 Nov 2025

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2018-19

For Appellant: Mr. Kirit ShethFor Respondent: 12/11/2025

account and estimation he issue of rejection of books of account and estimation he issue of rejection of books of account and estimation of income strictly in accordance with law. of income strictly in accordance with law. 5.3 With regard to the addition relating to M/s Vinayak With regard

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

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

ITA 322/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Nov 2025AY 2019-20
For Appellant: NoneFor Respondent: Mr. Uma Shankar Prasad, CIT-DR
Section 132Section 143(2)Section 145(3)Section 68

sales. Invoking section\n145(3) of the Act, he rejected the books of account and, treating the\nassessee as an entry operator, estimated commission income at 5%\nof the declared turnover of ₹51,78,40,543/-. The Assessing Officer further made an addition of ₹2,75,000/- under section ... facts and circumstances of the case and\nin2,24,77,726 law, the Learned Commissioner of Income Tax\n(Appeal) has wrongly estimated the income of the appellant @ 3%\nfor total turnover of Purchase and Sales as reported in profit and\nloss account, prepared from Audited Book of Accounts amounting

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

case and in law, the Learned Commiss Learned Commissioner of Income Tax (Appeal) has wrongly ioner of Income Tax (Appeal) has wrongly estimated the income of the appellant @ 3% for total turnover of estimated the income of the appellant @ 3% for total turnover of estimated the income of the appellant ... 322/MUM/2025 & ITA Nos. ITA Nos. 264, 318 to 322/MUM/2025 263, 280 to 284/MUM/2025 assessee as an entry operator, estimated commission income at 5% assessee as an entry operator, estimated commission income at 5% assessee as an entry operator, estimated commission income at 5% of the declared turnover

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
Section 132Section 145(3)Section 153ASection 68

Lakhs\n\nWhether on the facts and circumstances of the case and in law, the Learned Commissioner of Income Tax (Appeal) has wrongly estimated the income of the appellant @ 3% for total turnover of\n\nManish Kantilal Kapadia & Rekha Manish Kapadia 3\nITA Nos.264, 318 to 322/MUM/2025 & ITA Nos.\n263 ... sales. Invoking section 145(3) of the Act, he rejected the books of account and, treating the\n\nassesssee as an entry operator, estimated commission income at 5% of the declared turnover of ₹51,78,40,543/-, resulting in an addition of ₹2,58,92,027/-. The Assessing Officer further

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

Rs.4.10 Lakhs\nWhether on the facts and circumstances of the case and in law, the Learned Commissioner of Income Tax (Appeal) has wrongly estimated the income of the appellant @ 3% for total turnover of\nPurchase and Sales as reported in profit and loss account, prepared from Audited Book of Accounts ... 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 in an addition of ₹2,58,92,027/-. The Assessing Officer further made

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

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

ITA 318/MUM/2025[2015-16]Status: DisposedITAT Mumbai26 Nov 2025AY 2015-16
For Appellant: NoneFor Respondent: Mr. Uma Shankar Prasad, CIT-DR
Section 132Section 145(3)Section 68

nManish Kantilal Kapadia & Rekha Manish Kapadia 5\nITA Nos.264, 318 to 322/MUM/2025 & ITA Nos.\n263, 280 to 284/MUM/2025\nassessee as an entry operator, estimated commission income at 5%\nof the declared turnover of ₹51,78,40,543/-, resulting in an\naddition of ₹2,58,92,027/-. The Assessing Officer further ... facts and circumstances of the case and\nin2,24,77,726 law, the Learned Commissioner of Income Tax\n(Appeal) has wrongly estimated the income of the appellant @ 3%\nfor total turnover of Purchase and Sales as reported in profit and\nloss account, prepared from Audited Book of Accounts amounting

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

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

ITA 284/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Nov 2025AY 2019-20
Section 132Section 143(2)Section 145Section 145(3)Section 68

sales. Invoking section\n145(3) of the Act, he rejected the books of account and, treating the\nassessee as an entry operator, estimated commission income at 5%\nof the declared turnover of ₹51,78,40,543/-, resulting in an\naddition of ₹2,58,92,027/-. The Assessing Officer further made ... facts and circumstances of the case and\nin2,24,77,726 law, the Learned Commissioner of Income Tax\n(Appeal) has wrongly estimated the income of the appellant @ 3%\nfor total turnover of Purchase and Sales as reported in profit and\nloss account, prepared from Audited Book of Accounts amounting

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

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

ITA 283/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Nov 2025AY 2018-19
Section 132Section 143(2)Section 145(3)Section 68

sales. Invoking section\n145(3) of the Act, he rejected the books of account and, treating the\nassessee as an entry operator, estimated commission income at 5%\nof the declared turnover of ₹51,78,40,543/-, - resulting in an\naddition of ₹2,58,92,027/-. The Assessing Officer further made ... facts and circumstances of the case and\nin2,24,77,726 law, the Learned Commissioner of Income Tax\n(Appeal) has wrongly estimated the income of the appellant @ 3%\nfor total turnover of Purchase and Sales as reported in profit and\nloss account, prepared from Audited Book of Accounts amounting

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

case and in law, the Learned Commiss Learned Commissioner of Income Tax (Appeal) has wrongly ioner of Income Tax (Appeal) has wrongly estimated the income of the appellant @ 3% for total turnover of estimated the income of the appellant @ 3% for total turnover of estimated the income of the appellant ... 322/MUM/2025 & ITA Nos. ITA Nos. 264, 318 to 322/MUM/2025 263, 280 to 284/MUM/2025 assessee as an entry operator, estimated commission income at 5% assessee as an entry operator, estimated commission income at 5% assessee as an entry operator, estimated commission income at 5% of the declared turnover

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

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

ITA 263/MUM/2025[2014-15]Status: DisposedITAT Mumbai26 Nov 2025AY 2014-15
Section 132Section 143(2)Section 145(3)Section 68

sales. Invoking section\n145(3) of the Act, he rejected the books of account and, treating the\nassessee as an entry operator, estimated commission income at 5%\nof the declared turnover of ₹51,78,40,543/-. The Assessing Officer further\nmade an addition of ₹2,75,000/- under the section ... facts and circumstances of the case and\nin2,24,77,726 law, the Learned Commissioner of Income Tax\n(Appeal) has wrongly estimated the income of the appellant @ 3%\nfor total turnover of Purchase and Sales as reported in profit and\nloss account, prepared from Audited Book of Accounts amounting

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

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 by applying the average net profit rate of 5.48%, based on the preceding three assessment years, thereby determining the business income for the year ... section 145A(i) of the Act. The assessee therefore argued that the rejection of books of account by the AO and consequent estimation of income was unjustified and contrary to law. 17. The Ld.CIT(A) vide the impugned order dated 16.05.2025, upheld the action of the AO in rejecting

Bhaveshbhai Haribhai Kanani, Jamnagar vs. ITO Ward 2(10) Jamnagar, Jamnagar

In the result, appeal filed by the assessee is partially allowed in above terms

ITA 233/RJT/2025[2018-19]Status: DisposedITAT Rajkot24 Nov 2025AY 2018-19

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.233/Rjt/2025 िनधा"रण वष"/Assessment Year : 2018-19 बनाम/ Bhaveshbhai Haribhai Kanani Income Tax Officer Plot No. E211, Gidc Phase-2, Vs Ward – 2(10), Jamnagar Dared, Jamnagar, Gujarat - 361008 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Acypk5085F (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 250Section 44A

income. 9. We have submitted that the profit for current year as well as subsequent year must be taken as guiding principle for estimation of income. Since, appellant had not earned income at the rate of 6% as proposed by your honour. 10. We have submitted all purchase and sales ... assessing officer also noticed that assessee had admitted the fact of error in its ITR and the assessee has suggested to estimate the income as per audited profit and loss account of next financial year i.e FY 2018-19 and AY 2019-20, in which on turnover of Rs.6

Dhanashree Sandeep Shete, Sangli vs. ITO, Ward No- 1, Sangli

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1690/PUN/2025[2017-18]Status: DisposedITAT Pune24 Nov 2025AY 2017-18

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Narendra Joshi (Virtual)For Respondent: Shri Bharat Andhale
Section 147Section 148Section 44A

submitted, including bank statements, party-wise receipts, and government challans, clearly demonstrating the segregated nature of client funds and actual business income. The estimation of income without dissecting the actual inflows leads to an inflated tax liability. Ground 4: The Assessing Officer's original addition

Assistant Commissioner of Income Tax, Central Circle-3(1), Kolkata vs. Rajshri Iron Industries Private Limited, Kolkata

In the result, both the appeals of the Revenue are dismissed

ITA 2388/KOL/2024[2013]Status: DisposedITAT Kolkata21 Nov 2025

Bench: Shri Rajesh Kumar, Am & Shrisonjoy Sarma, Jm

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: S/Shri Praveen Kishore &
Section 147Section 148Section 148ASection 69C

have rejected the books of accounts of the Assessee in a manner contemplated u/s.145(3) of the Act and therefore estimation of income of the Assessee is not possible. The addition has been made by the CIT(A) on the basis of the following observations in his order: “6.2.5. Further ... basis of documents seized. The Ld. DR submitted that the ld. CIT(A) wrongly applied 5.06% on the purchases for estimation of income by holding that the entire purchases cannot be brought to tax ITA Nos.2385 & 2388/KOL/2024& CO Nos. 46 & 47/KOL/2025 Rajshri Iron Industries Private Limited; A.Ys

Assistant Commissioner of Income Tax, Central Circle-3(1), Kolkata vs. Rajshri Iron Industries Private Limited, Kolkata

In the result, both the appeals of the Revenue are dismissed

ITA 2385/KOL/2024[2018]Status: DisposedITAT Kolkata21 Nov 2025

Bench: Shri Rajesh Kumar, Am & Shrisonjoy Sarma, Jm

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: S/Shri Praveen Kishore &
Section 147Section 148Section 148ASection 69C

have rejected the books of accounts of the Assessee in a manner contemplated u/s.145(3) of the Act and therefore estimation of income of the Assessee is not possible. The addition has been made by the CIT(A) on the basis of the following observations in his order: “6.2.5. Further ... basis of documents seized. The Ld. DR submitted that the ld. CIT(A) wrongly applied 5.06% on the purchases for estimation of income by holding that the entire purchases cannot be brought to tax ITA Nos.2385 & 2388/KOL/2024& CO Nos. 46 & 47/KOL/2025 Rajshri Iron Industries Private Limited; A.Ys