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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

Vidhun Joseph Philip, Nilambur, Malappuram vs. ITO, Ward 2, Tirur, Malappuram

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

ITA 551/COCH/2025[2019-20]Status: DisposedITAT Cochin11 Aug 2025AY 2019-20

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2019-20 Vidhun Joseph Philip .......... Appellant Pioneer House, Chandakkunnu P.O. Nilambur Bungalow Road, Malappuram 67932 [Pan: Ayopv7170J] Vs. The Income Tax Officer, Ward-2, Tirur .......... Respondent Assessee By: Shri Richard Mathew, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 07.08.2025 Date Of Pronouncement: 11.08.2025 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 20.11.2024 For Assessment Year (Ay) 2019-20. 2. Brief Facts Of The Case Are That Appellant Is An Individual & No Return Of Income Was Filed Under The Provisions Of Section 139(1) Of The Act For Ay 2019-20. The Income Tax Officer, Ward-2, Tirur (Hereinafter Called "The Ao") Issued A Notice U/S. 148 Of The Income Tax Act, 1961 (The Act) Based On The Information That The Appellant Made Cash Deposits Of Rs. 1,06,09,350/- During The Previous Year Relevant To Ay 2019-20. Accordingly, A Notice U/S. 148 Of The Act

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

While doing so, the AO treated the cash deposits made in the bank account as business receipt of the appellant and estimated the income at 10% of the total sales. Accordingly, made addition of Rs. 14,23,061/-. 3. Being aggrieved, an appeal was filed before the CIT(A) contesting ... that the estimation of income at 10% is excessive. However, the CIT(A) confirmed the action of the AO. 4. Being aggrieved, the appellant is in appeal before this Tribunal in the present appeal. 5. When the appeal was called on, nobody appeared on behalf of the assessee despite