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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

DCIT, Chennai vs. Jagathrakskan Srinisha, Chennai

In the result, the appeals filed by the Revenue in I

ITA 1253/CHNY/2025[2017-18]Status: DisposedITAT Chennai18 Nov 2025AY 2017-18

Bench: Shri Aby T Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.: 1253, 1264 & 1271/Chny/2025 निर्धारण वर्ष / Assessment Year: 2017-18 Dcit, Central Circle -2(3), Chennai. (अपीलार्थी/Appellant) Vs. Jagathrakshakan Srinisha, 1St Main Road, Adyar, Besant Nagar, Chennai - 600 020. Tamil Nadu. [Pan: Abfps-1422-E] (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri. B. Ramakrishnan, Fca & Shri. Shrenik Chordia, Ca. राजस्व की ओर से / Revenue By : Shri. C.N. Bipin, C.I.T. सुनवाई की तारीख /Date Of Hearing : 07.11.2025 घोषणा की तारीख/Date Of Pronouncement : 18.11.2025 आदेश /Order Per S.R.Raghunatha, Am: The Present Appeal Is Preferred By The Revenue Against The Order Dated 06.02.2025 Passed By The Commissioner Of Income Tax (Appeals)-19 (Hereinafter Referred To As Ld.Cit(A), Chennai, In Respect Of The Assessment Order Dated 01.03.2019 Passed By The Deputy Commissioner Of Income Tax, Central Circle -2(3) (Hereinafter Referred To As Ao) For The Assessment Year 2017-18 (Hereinafter Referred To As The Impugned Assessment Year) U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As The Act). :-2-:

For Appellant: Shri. B. Ramakrishnan, FCA &For Respondent: Shri. C.N. Bipin, C.I.T
Section 131Section 132Section 143(3)Section 154Section 270A

Rs.72,45,018/- as ‘unaccounted business income', which was also upheld by us. Since, it is only a case of estimation of income, penalty u/s.270A of the Act is not invocable. Accordingly, we are inclined to dismiss the grounds of appeal raised by the Revenue and hence, the appeal

M/S B Krishnakumar, Mavelikara vs. Ward 1 & Tps, Thiruvalla

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

ITA 677/COCH/2025[2017-18]Status: DisposedITAT Cochin14 Nov 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am Assessment Years: 2017-18 B. Krishna Kumar .......... Appellant Makamkuzhy, Kallimel P.O., Mavelikara [Pan: Aapfm9503R] Vs. The Income Tax Officer, Wd-1 & Tps, Thiruvalla ....... Respondent Assessee By: Smt. Lakshmi N., Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 29.10.2025 Date Of Pronouncement: 14.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 31.07.2025 For Assessment Year (Ay) 2017-18. 2. Brief Facts Of The Case Are That The Appellant Is A Partnership Firm Engaged In The Business Of Petroleum Products. The Return Of Income For Ay 20170-18 Was Filed On 31.03.2018 Disclosing Income Of Rs. 1,83,110/-. No Assessment Was Made Against The Said Return Of Income. Subsequently, Based On The Information That The Appellant Firm Made Cash Deposits Amounting To Rs. 2,55,19,294/- In The Bank Account Maintained With State Bank Of India During The Previous

For Appellant: Smt. Lakshmi N., CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 142(1)Section 148

notices issued u/s. 142(1) of the Act calling for information. In the circumstances, the AO made best judgement assessment by estimating the income at 2% of the gross turnover of Rs. 9,36,11,035/- and made addition of Rs. 16,89,110/-. 3. Being aggrieved, an appeal ... before this Tribunal in the present appeal. 5. The learned counsel for the assessee contends before me that the AO ought not have estimated the income without rejecting the books of account as the books of accounts were audited. 6. On the other hand, the learned Sr. DR submits that

Islahi English Medium School, Kannur vs. ITO Ward 1 & Tps, Kannur

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

ITA 749/COCH/2025[2018-19]Status: DisposedITAT Cochin10 Nov 2025AY 2018-19

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2018-19 Islahi English Medium School .......... Appellant Irikkur P.O., Kannur 670593 [Pan: Aaaai9586J] Vs. Income Tax Officer, Ward-1 & Tps, Kannur .......... Respondent Assessee By: Shri Suresh Kumar,Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 04.11.2025 Date Of Pronouncement: 10.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 04.03.2025 For Assessment Year (Ay) 2018-19. 2. Brief Facts Of The Case Are That The Appellant Is An Association Of Persons Running An Educational Institution. No Regular Return Of Income Under The Provisions Of Section 139(1) Of The Income Tax Act, 1961 (The Act) Was Filed By The Appellant For Ay 2018-19. Based On The Information That The Appellant Made Cash Deposit Of Rs. 90,10,470/-, The Ao Formed An Opinion That Income Escaped Assessment To Tax. Accordingly, After Complying The Procedure Laid

For Appellant: Shri Suresh Kumar,CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 147Section 148Section 148A

passed u/s. 147 r.w.s. 144B of the Act at a total income of Rs. 9,28,107/-. While doing so, the AO estimated the income on the fees receipts of Rs. 1,09,85,494/- at 8% of the total income and also made addition on interest income received from ... estimation of 8% of the gross receipts is arbitrary and excessive. Without rejecting the books of account by the AO ought not have estimated the income. 6. On the other hand, the learned Sr. DR supporting the orders of the learned lower authorities submits that no interference is called

Chandanath Irshad, Thrissur vs. ITO, Ward-1&Tps, Guruvayoor

In the result, the appeal filed by the assessee stands dismissed

ITA 631/COCH/2025[2015-16]Status: DisposedITAT Cochin10 Nov 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am Assessment Years: 2015-16 Chandanth Irshad .......... Appellant Irshad Agencies, Chandanth, Andathode Thrissur 679564 [Pan: Aefpi2931B] Vs. Ito, Ward -1 & Tps, Guruvayoor .......... Respondent Assessee By: Shri Narayanan P. Potty, Advocate Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 28.10.2025 Date Of Pronouncement: 10.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 11.07.2025 For Assessment Year (Ay) 2015-16. 2. Brief Facts Of The Case Are That The Appellant Is An Individual & Proprietor Of The Firm Irshal Agencies Carrying On The Business Of Trading In Cattle Feed. No Regular Return Of Income For Ay 2015- 16 Was Filed By The Appellant. Subsequently, The Ao, Based On The Information Available In The Aims Module Of Itba That The Appellant Had Deposited Cash In Sb Account Aggregating To Rs. 1,43,41,285/-, Formed An Opinion That Income Escaped Assessment To 2 Chandanth Irshad Tax. Accordingly, A Notice U/S. 148 Of The Income Tax Act, 1961 (The Act) Was Issued On 31.03.2021. In Response To The Notice U/S. 148, The Appellant Filed The Return Of Income On 09.08.2021 Declaring Income Of Rs. 2,34,600/-. The Appellant Had Not Furnished The Information Sought By The Assessing Authority In Response To The Notice Issued U/S. 142(1) Of The Act. In The Circumstances, The Ao Treated The Entire Cash Deposits As Business Turnover Of The Appellant & Estimated The Income At 8%. Accordingly, He Made Addition Of Rs. 9,15,532/-.

For Appellant: Shri Narayanan P. Potty, AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R
Section 142(1)Section 148

circumstances, the AO treated the entire cash deposits as business turnover of the appellant and estimated the income at 8%. Accordingly, he made addition of Rs. 9,15,532/-. 3. Being aggrieved, an appeal was filed before the CIT(A), who vide the impugned order confirmed the action ... appeal before this Tribunal in the present appeal. 5. The learned counsel for the assessee contended that the AO ought not have estimated the income of the appellant in view of the fact that the books of account were audited. Further, it is submitted that estimation of profit