← 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

Kamalakannan Ramesh, Chennai vs. ACIT, Ncc-1, Chennai

In the result, appeal filed by the assessee is allowed

ITA 1538/CHNY/2024[2012-13]Status: DisposedITAT Chennai23 Oct 2024AY 2012-13

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

Section 144Section 145(3)Section 148

same, which the AO failed to do. Therefore, the Ld AR contented that AO’s action of rejecting the log-book and consequent estimation of income is bad in law. We find considerable force in the contention of assessee and note that assessee produced the log-book maintained

Partap Singh, Faridabad vs. Income Tax Officer, Faridabad

ITA 1858/DEL/2024[2012-13]Status: DisposedITAT Delhi23 Oct 2024AY 2012-13

Bench: Shri Anubhav Sharma & Shri Brajesh Kumar Singhassessment Year: 2012-13

Section 143(3)Section 147Section 148Section 271(1)(c)Section 274Section 54F

amount of cash/credit entries to the tune of Rs. Rs.1,18,33,000/- remains unsubstantiated and unexplained. 8.2 Before I proceed to make estimation of income, I may refer to relevant legal propositions in this regard. In the case of Prabhat Kumar, where the assessee failed to produce the books

Thangavel Kandasamy, Coimbatore vs. ITO, Ncw 4(1), Coimbatore

In the result, the appeal filed by the assessee is partly allowed

ITA 2019/CHNY/2024[2017-18]Status: DisposedITAT Chennai21 Oct 2024AY 2017-18

Bench: Shri Mahavir Singh & Shri Jagadishआयकर अपील सं./Ita No.2019/Chny/2024 िनधा9रण वष9 /Assessment Year: 2017-18

For Appellant: Shri S. Sridhar, Advocate (Erode)For Respondent: Ms. R. Anita, Addl. CIT
Section 142(1)Section 144

ground of appeal in this appeal of assessee is against addition of cash deposit during demonetization period of Rs. 16,40,500/- and estimation of income @ 30% in the bank deposit. 3. The assessee is individual and has total credit of Rs. 1,21,31,504 in his bank account ... orders of lower authorities. 6. We have heard the rival submissions, and perused the materials available on record. The A.O has estimated the income @ 30% of the total credit in the bank account minus cash deposit of Rs. 16,40,500/- during demonetization period. The assessee has explained that

M/S. Nikshal Properties Pvt. Ltd, Vadodara vs. The DCIT, Circle-3(1)(1), Ahmedabad

In the result, the appeal filed by the assessee is allowed

ITA 2240/AHD/2018[2015-16]Status: DisposedITAT Ahmedabad18 Oct 2024AY 2015-16

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2015-16 M/S. Nikshal Properties Pvt. Ltd. The Dy. Commissioner Of 42-B, Triloknagar Society Vs Income-Tax Near Aruvedik Hospital Circle-3(1)(1) Outside Pani Gate, Ahmedabad Vadodara – 390 019 Pan: Aadcn 3151 F अपीलाथ"/ (Appellant) अपीलाथ" "" यथ" "" यथ"/ (Respondent) अपीलाथ" अपीलाथ" "" "" यथ" यथ" Assessee By : Shri Paras F. Jain,Ar Revenue By : Shri Ashok Kumar Suthar, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 16/10/2024 घोषणा क" तारीख /Date Of Pronouncement: 18/10/2024 आदेश/O R D E R आदेश आदेश आदेश Per Annapurna Guptathis Appeal Filed By The Assessee Is Directed Against The Order Of Learned Commissioner Of Income-Tax (Appeals)-9, Ahmedabad [Hereinafter Referred To As “Ld. Cit(A)” For Short] Dated 25/09/2018 Passed For Assessment Year (Ay) 2015-16. 2. The Assessee Has Raised The Following Grounds Of Appeal: “1 The Ld. Cit(Appeals) Has Erred In Law & Facts In Upholding The Order Of The A.O. Assessing Income At Rs. 1,25,45,835/- As Against Nil Returned Income Declared By The Assessee After Set Off Of Brought Forward Business Loss Of Rs. 76,75,095/- 2. He Has Erred In Upholding The Estimation Of Commission @ 2% On Total Deposits In The Bank As Against 0.5% Agreed By The Assessee Without Properly Appreciating The Facts & Estimation Of Income At 0.5% In Similar Other Cases. He Has Erred In Law & Facts In Not Properly Appreciating & Accepting The Written Submission Furnished By The Assessee During Course Of Assessment Proceedings. M/S.Nikshal Properties Pvt.Ltd. Vs. Dcit Ay 2015-16 2

For Appellant: Shri Paras F. Jain,ARFor Respondent: Shri Ashok Kumar Suthar, Sr.DR
Section 234A

estimation of commission @ 2% on total deposits in the bank as against 0.5% agreed by the assessee without properly appreciating the facts and estimation of income at 0.5% in similar other cases. He has erred in law and facts in not properly appreciating and accepting the written submission furnished ... assessment order has observed that the appellant is engaged in the business of providing accommodation entries and he accordingly estimated the Income @2% of the total receipt and commission. The appellant before the A.O itself has agreed for addition of commission @0.5%. Appellant during the appellate proceedings has not made

Ashok Kumar Gupta, Kolkata vs. ITO, Ward - 43(1), Kolkata

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

ITA 1081/KOL/2024[2017-2018]Status: DisposedITAT Kolkata18 Oct 2024AY 2017-2018

Bench: Shri Rajpal Yadav & Shri Rakesh Mishraassessment Year: 2017-18

For Appellant: Deep Agarwal, AdvocateFor Respondent: Pradip Kumar Biswas, Addl. CIT
Section 133(6)Section 143(3)Section 250

deposit. As the income has not been properly estimated and even though the assessee is not pressing the ground of appeal relating to estimation of income on the excess turnover, we deem it proper that the entire assessment order is set aside to the Ld. AO to be made

Castle Commodities Pvt. Ltd., Kolkata vs. ITO, Ward-6(1), Kolkata.

In the result, the appeal of the assessee is allowed

ITA 1192/KOL/2023[2018-19]Status: DisposedITAT Kolkata18 Oct 2024AY 2018-19

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 133(6)Section 69

which no income or loss has been shown during the year. The AO stated that the said transaction to be not tenable and estimated the income @20% on the said sales, thereby making the addition of Rs. 27,42,39,740/-. 11. The Ld. CIT(A) in the appellate proceedings ... income or loss are shown. The Ld. A.R argued that in respect of bringing any cogent material on record to corroborate the estimation of income. The AO simply acting his whims and fancies and on surmises estimated the income @20% without any basis which is against the provision

Chandan Chouhan, Khargone vs. DCIT, Delhi

The appeal of the assessee is partly allowed

ITA 210/IND/2024[2014-15]Status: DisposedITAT Indore18 Oct 2024AY 2014-15

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanishri Chandan Chouhan, Dcit, Ward No.24, Nfac Vs. Nath Gali, Delhi Khargone (Appellant / Assessee) (Respondent/ Revenue) Pan: Auxpc9073A Assessee By Shri Ashok Surjan, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 07.10.2024 Date Of Pronouncement 18.10.2024 O R D E R

Section 131Section 139Section 142(1)Section 143(2)Section 144Section 147Section 148Section 250

taken into consideration by the A.O while framing the assessment u/s 147 3 ChandanChouhan r.w.s. 144/144B of the Act. The A.O estimated the income of the assessee by taking net profit @8% on the turnover of Rs.12,51,76,710/- and assessed the total income at Rs.1 ... Before the Tribunal the Ld. AR of the assessee has submitted that the A.O made an arbitratory addition by estimating the income of the assessee @8% whereas the assessee has declared the net profit @0.23% on the whole sale business of sugar. He has referred to the return of income

Ratan Kumar Yadav, Jaipur vs. Income Tax Officer, Ward-2(2), Jaipur

In the result, the appeal of the assessee is allowed

ITA 1159/JPR/2024[2017-18]Status: DisposedITAT Jaipur18 Oct 2024AY 2017-18

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri S.R. Sharma, CA &For Respondent: Shri Gautam Singh Choudhary, JCIT D/R
Section 145(3)Section 250Section 44

case of Sanjay Agarwal Vs. ITO, Ward-3(3), Jaipur held that “Section 145 of the Income-tax Act, 1961 – Method of accounting – Estimation of income (GP rate) – Assessment year 2012-13 – Whether once books of account are rejected, Assessing Officer has to 6 Ratan Kumar Yadav, Jaipur. estimate profits ... case of Sanjay Agarwal Vs. ITO, Ward-3(3), Jaipur held that “Section 145 of the Income-tax Act, 1961 – Method of accounting – Estimation of income (GP rate) – Assessment year 2012-13 – Whether once books of account are rejected, Assessing Officer has to estimate profits based on his judgment

Pme Power Solutions India Ltd, New Delhi vs. Deputy Commissioner of Income Tax, New Delhi

In the result, both the appeal of the assessee are allowed

ITA 249/DEL/2024[2013-14]Status: DisposedITAT Delhi16 Oct 2024AY 2013-14

Bench: Shri M. Balaganesh & Shri Vimal Kumar

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri Rajesh Dhanesta, Sr. DR
Section 139Section 139(9)Section 140ASection 143(1)Section 143(2)Section 143(3)Section 154Section 249(4)(a)Section 271(1)(c)Section 276C(2)

made without the benefit of return of income and the Assessing Officer can resort to a rejection of books of account and estimation of income. In a best judgement assessment, the interest is calculated under section 234A of the Act till the date of completion of the assessment whereas

Pme Power Solutions India Ltd, New Delhi vs. Dy. Commissioner of Income Tax, New Delhi

In the result, both the appeal of the assessee are allowed

ITA 242/DEL/2024[2013-14]Status: DisposedITAT Delhi16 Oct 2024AY 2013-14

Bench: Shri M. Balaganesh & Shri Vimal Kumar

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri Rajesh Dhanesta, Sr. DR
Section 139Section 139(9)Section 140ASection 143(1)Section 143(2)Section 143(3)Section 154Section 249(4)(a)Section 271(1)(c)Section 276C(2)

made without the benefit of return of income and the Assessing Officer can resort to a rejection of books of account and estimation of income. In a best judgement assessment, the interest is calculated under section 234A of the Act till the date of completion of the assessment whereas

Income Tax Officer, Ward-1, Nagapattinam vs. Rajendran Manikandan, Vadakudi, Annavasal

The appeal stand partly allowed

ITA 1130/CHNY/2024[2017-18]Status: DisposedITAT Chennai09 Oct 2024AY 2017-18

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.1130/Chny/2024 (िनधा*रणवष* / Assessment Year: 2017-18) Ito Shri Rajendran Manikandan बनाम Ward -1, 2/105 West Street, Nagapattinam. Vadakudi, Annavasal, Arangakudi, / Vs. Nagapattinam - 609 302. "थायीलेखासं./जीआइआरसं./Tan/Gir No.Cxxpm-5154-P (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Ms. R. Anita ( Addl.Cit) -Ld. Sr. Dr " थ"कीओरसे/Respondent By : Shri S. Sridhar (Advocate) – Ld.Ar सुनवाईकीतारीख/Date Of Hearing : 26-09-2024 घोषणाकीतारीख /Date Of Pronouncement : 09-10-2024 आदेश / O R D E R

For Appellant: Ms. R. Anita ( Addl.CIT) -Ld. Sr. DRFor Respondent: Shri S. Sridhar (Advocate) – Ld.AR
Section 144Section 69A

evident that the assessment has been framed on best judgment basis. 2. The Ld. AR advanced arguments and pleaded for reasonable estimation of income. The same has been opposed by Ld. Sr. DR. Having heard rival submissions and upon perusal of case records, our adjudication would be as under ... Apparently, the assessee has not maintained any books of accounts. Considering the same and with a view to end litigation, we estimate the income of the assessee @8% on cash deposits of Rs.1,33,79.100/-. The same comes to Rs.10,70,328/-, Adding the same to Rs.1

Deputy Commissioner of Income Tax, Central Circle-4, Jaipur vs. Sunder Das Sonkiya, Jaipur

In the result, both appeals of the revenue are dismissed

ITA 454/JPR/2024[2013-14]Status: DisposedITAT Jaipur09 Oct 2024AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. S. R. Sharma, CA &For Respondent: Sh. Anup Singh, Addl.CIT
Section 143(1)Section 143(2)Section 143(3)Section 148

Jaipur and Hon'ble Rajasthan High Court wherein it was held that when purchases are unverifiable, income is to be estimated and for estimation of income of the assessee, application of G.P. is the best course of action based on average G.P. rate on past history. Base upon the same ... Jaipur and Hon'ble Rajasthan High Court wherein it was held that when purchases are unverifiable, income is to be estimated and for estimation of income of the assessee, application of G.P. is the best course of action based on average G.P. rate on past history. Base upon the same

Deputy Commissioner of Income Tax, Central Circle-4, Jaipur vs. Sunder Das Sonkiya, Jaipur

In the result, both appeals of the revenue are dismissed

ITA 453/JPR/2024[2012-13]Status: DisposedITAT Jaipur09 Oct 2024AY 2012-13

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Revenue Has Assailed The Appeal In Ita No.453/Jp/2024 On The Following Grounds; “(I) Whether On The Facts & In The Circumstances Of The Case, The Ld. Cit(A) Is Justified In Deleting The Addition Of Rs.43,33,606/- Without Appreciating The Fact That Assessee Has Shown Bogus Purchase Of Rs 1,73,34,424/- During The Year From A Bogus Concern. 3

Section 132Section 143(1)Section 143(2)Section 148

Jaipur and Hon'ble Rajasthan High Court wherein it was held that when purchases are unverifiable, income is to be estimated and for estimation of income of the assessee, application of G.P. is the best course of action based on average G.P. rate on past history. Base upon the same ... Jaipur and Hon'ble Rajasthan High Court wherein it was held that when purchases are unverifiable, income is to be estimated and for estimation of income of the assessee, application of G.P. is the best course of action based on average G.P. rate on past history. Base upon the same

ACIT CC-3, Thane vs. Jagdale Infrastructure Pvt. Ltd, Thane

ITA 4446/MUM/2024[2019-20]Status: DisposedITAT Mumbai09 Oct 2024AY 2019-20

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

Section 133ASection 145(3)

determine income as per percentage completion method is not as per Guidance Note on Accounting for Real Estate Transactions issued by ICAI (b) Estimation of income is done by the Id AO without rejecting book results u/s 145(3) (c) That booking advances not supported by executed agreement for sale

Gng Exports, Kolkata vs. ACIT, Cir. 33, Kolkata

In the result, the appeal of the assessee stands dismissed

ITA 475/KOL/2024[2013-14]Status: DisposedITAT Kolkata08 Oct 2024AY 2013-14

Bench: Shri Sanjay Garg & Shri Rakesh Mishrai.T.A. No.475/Kol/2024 Assessment Year: 2013-14 Gng Exports……..……………….………...........………………....Appellant 202, Lords, 7/1, Lord Sinha Road, Rabindra Sadan, Kolkata – 700071. [Pan: Aacfg59994P] Vs. Acit, Circle-33, Kolkata.……………….…............................…..…..... Respondent Appearances By: Shri Ramesh Kumar Patodia, Advocate, Appeared On Behalf Of The Assessee. Shri Vineet Kumar, Addl. Cit- Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : July 09, 2024 Date Of Pronouncing The Order : October 08, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 11.01.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Is Aggrieved By The Action Of The Ld. Cit(A) In Directing The Assessing Officer To Estimate The Net Profit Of The Assessee @ 0.77% Of The Total Turnover.

Section 133(6)Section 250

I.T.A. No.475/Kol/2024 Assessment Year: 2013-14 GNG Exports issued u/s 133(6) of the Act to some of the sundry creditors and subsequent estimation of income of the assessee @ 2% of the contracted work/turnover, was not tenable. He, however, accepted the alternate contention of the assessee, as was submitted before ... account of non-compliance/unservice of notices issued u/s 133(6) of the Act to some of the sundry creditors and subsequent estimation of income of the appellant @ 2% of the contract work is not tenable’, he was not justified in estimating the profits @ 0.77% of the total turnover

Venkata Prabhakar Rao Amancharla, Nellore vs. Income Tax Officer, Ward-5, Nellore

In the result, appeal of the assessee is allowed in part

ITA 1669/HYD/2019[2014-15]Status: DisposedITAT Hyderabad07 Oct 2024AY 2014-15

Bench: Shri K.Narasimha Charyआ.अपी.सं / Ita No.1669/Hyd/2019 (निर्धारण वर्ा / Assessment Year: 2014-15) Amancharla Venkata Prabhakar Rao Vs. Income Tax Officer Nellore Ward-5 [Pan : Agspa2284N] Nellore अपीलधर्थी / Appellant प्रत्‍यर्थी / Respondent निर्धाररती द्वधरध/Assessee By: Shri Vvsc Muralidhar Rao, Ar रधजस्‍व द्वधरध/Revenue By: Shri Aditi Goyal, Dr

For Appellant: Shri VVSC Muralidhar Rao, ARFor Respondent: Shri Aditi Goyal, DR
Section 144Section 50C

Reddy, Rs.2.87 lakhs towards unexplained deposits in SBI account, Rs.10.72 lakhs towards unexplained deposits in Axis bank, Rs.4,00,000/- by way of estimation of income from aqua business. 3. Assessee preferred appeal before the learned CIT(A) challenging these additions, but the learned CIT(A) did not agree with

Bhumikatransport Jv Bnra, Thane vs. Assistant Commisioner of Income Circle 19(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 1870/MUM/2024[2017-2018]Status: DisposedITAT Mumbai07 Oct 2024AY 2017-2018

Bench: Shri Sandeep Singh Karhail & Smt. Renu Jauhribhumika Transport Jv V/S. Acit, Circle 19(1) बनाम Bnra 203, 2Nd Floor, Matru House No. 610/C Wing, Mandir, Tardeo Road, Flat No. 604, 6Th Floor, Mumbai-400007 Siddhivinayal Complex, Phase Ii, Temghar, Kalyan, Thane-421302 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabab5560A Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Rahul HakaniFor Respondent: Shri R. R. Makwana
Section 141(1)Section 144Section 250

Page 2 of 4 A.Y. 2017-18 Bhumika Transport JV BNRA 6. Before us, the only ground of appeal relates to estimation of income @8% of Rs. 67,91,980/-. The Ld. AR submitted that the business of the assessee had stopped in the earlier year, as such, there ... cash deposits of Rs. 22,99,000/- pertain to previous assessment year and no addition can be made in the current year by estimation of income out of these deposits. Further, there is no dispute regarding the fact that the total amount of Rs. 54,01,980/- credited

Suwalka and Suwalka Properties and Builders Pvt Ltd, Kota, Rajasthan vs. ACIT, Central Cirlce, Kota, Rajasthan

ITA 302/JPR/2024[2017-18]Status: DisposedITAT Jaipur03 Oct 2024AY 2017-18

Bench: Him Challenging The 2 Suwalka & Suwalka Properties & Builders Pvt. Ltd. Vs. Acit Assessment Order Dated 22.12.2019 Passed U/S.143(3)Of The Income Tax

For Appellant: Sh. Vijay Goyal, CAFor Respondent: Sh. Anup Singh, Addl. CIT
Section 115BSection 129Section 142Section 142(1)Section 143(2)Section 143(3)Section 145(3)Section 68Section 69A

assessment by rejecting the books of account and consequently the income of the assessee was enhanced by applying the G.P. rate to estimate the income of the assessee. Therefore, it is clear that the said issue and aspect of not accepting the book results of the assessee was never taken

Bhavesh Jagmalbhai Gohil, Ahmedabad vs. Commissioner of Income Tax (Appeals), Ahmedabad

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

ITA 344/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad01 Oct 2024AY 2017-18

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 344/Ahd/2024 (िनधा"रण वष" / Assessment Year : 2017-18) बनाम/ Bhavesh Jagmalbhai Commissioner Of Income Gohil Vs. Tax (Appeals) 4, Vaibhav Bungalows, Ahmedabad Near Gulab Tower, Sola Road, Thaltej, Ahmedabad, Gujarat, 380059 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Alqpg3761M (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Hardik Vora, A.R. ""थ" की ओर से/Respondent By : Shri N. J. Vyas, Sr. Dr Date Of Hearing 12/09/2024 Date Of Pronouncement 01/10/2024

For Appellant: Shri Hardik Vora, A.RFor Respondent: Shri N. J. Vyas, Sr. DR
Section 143(3)Section 44ASection 57

ordered to be deleted. 2. The CIT(A) NFAC has erred in not appreciating the explanation submitted before AO requesting for estimation of income a/s 44AD, therefore the order of CIT(A) NFAC may be set aside and impugned addition by AD be ordered to be deleted

Shri. Irulandi Thevar Vetrivel, Madurai vs. ACIT, Central Cricle 2, Madurai

In the result, all the appeals of the Revenue are dismissed and the appeals of the assessee are partly allowed

ITA 240/CHNY/2024[2021-22]Status: DisposedITAT Chennai01 Oct 2024AY 2021-22

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Shri Y Sridhar, FCAFor Respondent: Shri R Clement Ramesh
Section 132Section 139Section 139(1)Section 153ASection 37Section 65B

disallowed the entire value of the bulk expenses and that the Ld. CIT(A)’s action of rejecting the books of accounts and estimating the income at 12.5% was unjustified and urged that the orders of the AO be restored. The Ld. CIT, DR further argued that, even otherwise ... unsustainable. The Ld. AR however objected to the Ld. CIT(A)’s action of rejecting the books of accounts and estimating the income at 12.5%. According to him, the assessee had already estimated and offered additional income by pegging the net profit margin at the rate