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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

M/S. Nucleus Fincons Pvt Ltd, Mumbai vs. ITO Ward 15(2)(2), Mumbai

In the result, the Assessee’s appeal is allowed for statistical purposes

ITA 5025/MUM/2025[2012-13]Status: DisposedITAT Mumbai21 Jan 2026AY 2012-13

Bench: Shri Narender Kumar Choudhryassessment Year: 2012-13 M/S. Nucleus Fincons Pvt. Ito 15(2) (2), Ltd. Aaykar Bhavan, M.K. Road, (Since Strike Off By Roc From Mumbai – 400020. 24/02/2017 Through Erstwhile Director, Kishore Patki), Vs. 503, Ankita Apartments, Opp. Gymkhana, Navghar Road, Mulund, Mumbai – 400081. Pan – Aabc6734A (Appellant) (Respondent) Present For: Assessee By : Shri Nishit Gandhi, Ld. A.R. Revenue By : Shri A.M.K. Mahadevan, Sr. D.R. Date Of Hearing : 20.11.2025 Date Of Pronouncement : 21.01.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 22.09.2023, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2012-13. 2. In The Instant Case, The Ao Vide Assessment Order Dated 27.11.2019 Under Section 147 R.W.S. 147 Of The Act Has Made The Additions Of Rs.7,00,000,/- & Rs.19,88,290/- Respectively As Unexplained Income Under Section 68 Of The Act & Estimation Of Income @ 1 + 1 % Of Rs.9,94,14,500/- On Credit & Debit Side. 2 M/S. Nucleus Fincons Pvt. Ltd

For Appellant: Shri Nishit Gandhi, Ld. A.RFor Respondent: Shri A.M.K. Mahadevan, Sr. D.R
Section 147Section 250Section 68

made the additions of Rs.7,00,000,/- and Rs.19,88,290/- respectively as unexplained income under Section 68 of the Act and estimation of income @ 1 + 1 % of Rs.9,94,14,500/- on credit and debit side. 2 M/s. Nucleus Fincons Pvt. Ltd 3. The Assessee being aggrieved against