← All Phrases

“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

Bhupinder Singh Sidhu(HUF), Mohali vs. ITO, Ward 4(1), Chandigarh

In the result, appeal of the Assessee is allowed

ITA 1024/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh29 Oct 2025AY 2020-21

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1024/Chd/2025 "नधा"रण वष" / Assessment Year : 2020-21 Bhupinder Singh Sidhu Huf, The Ito, बनाम House No. 1114, Sector 69, Ward 4(1) Mohali Chandigarh Vs. Punjab160069 "थायी लेखा सं./ Pan No: Aaghb9562C अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. M.R. Sharma, Advocate राज"व क" ओर से/ Revenue By : Sh. Vivek Vardhan, Add. Cit Dr, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 15.10.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 29.10.2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 4.7.2025 Passed By The Ld. Commissioner Of Income Tax, National Faceless Appeal Centre (Nfac), Delhi For A.Y. 2020-21. 2. Grounds Of Appeal Are As Under:

For Appellant: Sh. M.R. Sharma, AdvocateFor Respondent: Sh. Vivek Vardhan, Add. CIT DR, Sr.DR
Section 143

justice. 1024/Chd/2025 Bhupinder Singh Sidhu (HUF), Mohali 2 2. That the order of the Assessing Officer as upheld by the CIT(A) estimating the income from 40 acrs of agricultural land at Rs 1000000/- against the net returned agriculture income at Rs 3700000/- (Rs. 6000000/-, Rs. 2300000/- expenses) more ... earning agriculture income. Thus, to keep the principles of natural justice in consideration and material available on records only way was to estimate the income from agriculture activities. It was worth to mention there that there are various judicial pronouncement, which also allows the AO to estimate the income from

Thiruvengatam Vinayagam, Chennai vs. ITO, Ncw-10(3), Chennai

In the result, the appeal of the assessee is partly allowed

ITA 2284/CHNY/2025[2012-13]Status: DisposedITAT Chennai24 Oct 2025AY 2012-13

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकरअपीलसं./Ita No.:2283 & 2284 /Chny/2025 यनिाारणवर्ा / Assessment Year:2011-12 & 2012-13 Thiruvengatamvinayagam, Income Tax Officer, No.2/9, Bye Pass Road, Vs. Non-Corporate Ward-10(3), Redhills, Chennai. Chennai-600 052. [Pan:Aagpv1428F] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/Appellant By : Mr.Hithesh, Advocate प्रत्यर्थीकीओरसे/Revenue By : Mr.C.P.Solomon, Jcit

For Appellant: Mr.Hithesh, AdvocateFor Respondent: Mr.C.P.Solomon, JCIT
Section 143(1)Section 143(3)Section 148Section 40aSection 44A

learned CIT(A) has erred in law and on facts in upholding the action of the learned Assessing Officer in not estimating the income of the assessee considering the nature of the assessee's business of plying goods carriages and the reasonableness of income estimation based on industry standards ... 75/CHNY/2019 dated 30.05.2019, 4. The learned CIT(A) has erred in not directing the Assessing Officer to estimate the income of the assessee by taking guidance from the presumptive taxation scheme under Section 44AE, to ensure a fair, equitable, and non-arbitrary estimation. 5. That the income as estimated

Thiruvengatam Vinayagam, Chennai vs. ITO, Ncw-10(3), Chennai

In the result, the appeal of the assessee is partly allowed

ITA 2283/CHNY/2025[2011-12]Status: DisposedITAT Chennai24 Oct 2025AY 2011-12

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकरअपीलसं./Ita No.:2283 & 2284 /Chny/2025 यनिाारणवर्ा / Assessment Year:2011-12 & 2012-13 Thiruvengatamvinayagam, Income Tax Officer, No.2/9, Bye Pass Road, Vs. Non-Corporate Ward-10(3), Redhills, Chennai. Chennai-600 052. [Pan:Aagpv1428F] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/Appellant By : Mr.Hithesh, Advocate प्रत्यर्थीकीओरसे/Revenue By : Mr.C.P.Solomon, Jcit

For Appellant: Mr.Hithesh, AdvocateFor Respondent: Mr.C.P.Solomon, JCIT
Section 143(1)Section 143(3)Section 148Section 40aSection 44A

learned CIT(A) has erred in law and on facts in upholding the action of the learned Assessing Officer in not estimating the income of the assessee considering the nature of the assessee's business of plying goods carriages and the reasonableness of income estimation based on industry standards ... 75/CHNY/2019 dated 30.05.2019, 4. The learned CIT(A) has erred in not directing the Assessing Officer to estimate the income of the assessee by taking guidance from the presumptive taxation scheme under Section 44AE, to ensure a fair, equitable, and non-arbitrary estimation. 5. That the income as estimated