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“Section 145(3)”

Section References (mined)Section 145Section 145(3)2,270 judgments

The decision most relied on for Section 145(3) is CIT v. Woodward Governor India Pvt. Ltd. (312 ITR 254), cited in 968 judgments on BharatTax.

Leading authorities on Section 145(3)

CIT v. Woodward Governor India Pvt. Ltd.
312 ITR 254 · 2009 · Supreme Court
968
citing judgments

Foreign exchange fluctuations, whether gains or losses, are inextricably linked to the underlying business transaction and must be accounted for under the mercantile system. The Supreme Court also affirmed the standard accounting principle of valuing stock at cost or net realisable value, whichever is lower.

CIT v. Jet Airways (I) Ltd.
331 ITR 236 · 2011 · High Court
694
citing judgments

The Assessing Officer loses jurisdiction and the entire reassessment becomes invalid if no addition is made in respect of the income that formed the basis of the reopening. Explanation 3 to Section 147 does not permit assessing other escaped income unless an addition is made for the original income forming the reason to believe.

Kedarnath Jute Mfg. Co. Ltd. v. CIT
82 ITR 363 · 1971 · Supreme Court
654
citing judgments

Tax liability for an item of income or expenditure is determined solely by the provisions of the Income-tax Act. Entries in an assessee's books of account are not conclusive and do not govern the taxability or deductibility of an item, as the legal rights and obligations under the Act prevail.

Lalchand Bhagat Ambica Ram v. CIT
37 ITR 288 · 1959 · Supreme Court
570
citing judgments

Where an assessee maintains regular books of account, and these books are not rejected or found defective by the Assessing Officer, any cash deposits or available cash shown in the cash book, if sufficient to cover the transaction, cannot be treated as unexplained income or an addition under sections 68 or 69A.

CIT v. President Industries
258 ITR 654 · 2002 · High Court
471
citing judgments

When books of account are rejected and unaccounted sales or receipts are discovered, the income addition is restricted to the net profit element embedded in these undisclosed transactions, not the entire sale proceeds or receipts, especially if corresponding purchases are not proven to be outside the books.

Vijay Proteins Ltd. v. Asst. CIT
58 ITD 428 · 1996 · ITAT
430
citing judgments

Where purchases are found to be non-genuine or fictitious, a reasonable disallowance of 25% of such purchases or the peak credit, whichever is higher, can be made. This is applied to address unexplained expenditure under Section 69C when actual goods are likely procured from the grey market.

CIT v. Nikunj Exim Enterprises Pvt. Ltd.
372 ITR 619 · 2015 · High Court
391
citing judgments

Transactions defying human probability cannot be applied to isolated purchases if sales are accepted as genuine, and purchases cannot be disallowed without considering the entire transaction and documentary evidence. Failure to produce parties in an assessment proceeding may not be fatal to the assessee.

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.

Judgments citing Section 145(3)

Manish Kantilal Kapadia, Mumbai vs. ACIT CC 8(2), Mumbai

In the result, all the appeals for AY 2014-15 are allowed partly for statistical purposes whereas other appeals are dismissed

ITA 319/MUM/2025[2016-17]Status: DisposedITAT Mumbai26 Nov 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

Section 132Section 142(1)Section 143(2)Section 145Section 145(3)Section 153ASection 68

disapproving the learn Assessing officer's view of rejecting the Books of Accounts and Income of appellant by invoking the provision of section 145 (3) of the income tax Act, 1961. 5. The Learned Commissioner of Income Tax (Appeal) has again erred in allowing the respondent made an addition u/s.68 ... assessment, the Assessing Officer held that the transactions recorded by the assessee represented accommodation entries in respect of bogus purchases and sales. Invoking section 145(3) of the Act, he rejected the books of account and, treating the assessee as an entry operator, estimated commission income

Manish Kantilal Kapadia, Mumbai vs. ACIT CC -8(2), Mumbai

In the result, all the appeals for AY 2014-15 are allowed partly

ITA 318/MUM/2025[2015-16]Status: DisposedITAT Mumbai26 Nov 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: NoneFor Respondent: Mr. Uma Shankar Prasad, CIT-DR
Section 132Section 145(3)Section 153ASection 68

assessment, the Assessing Officer held that the transactions recorded by the assessee represented accommodation entries in respect of bogus purchases and sales. Invoking section 145(3) of the Act, he rejected the books of account and, treating the 5 Manish Kantilal Kapadia & Rekha Manish Kapadia 5 ITA Nos.264 ... findings, the Ld. CIT(A) held that the books of account maintained by the assessee were unreliable and had been rightly rejected under section 145(3) of the Act. 4.6 Regarding the turnover disclosed by the assessee, the Ld. CIT(A) noted that although only part of the sales pertained

Rekha Manish Kapadia, Mumbai vs. ACIT-CC-8(2), Mumbai

In the result, all the appeals for AY 2014-15 are allowed partly

ITA 284/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Nov 2025AY 2019-20

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

Section 132Section 142(1)Section 143(2)Section 145Section 145(3)Section 153ASection 68

disapproving the learn Assessing officer's view of rejecting the Books of Accounts and Income of appellant by invoking the provision of section 145 (3) of the income tax Act, 1961. 5. The Learned Commissioner of Income Tax (Appeal) has again erred in allowing the respondent made an addition u/s.68 ... assessment, the Assessing Officer held that the transactions recorded by the assessee represented accommodation entries in respect of bogus purchases and sales. Invoking section 145(3) of the Act, he rejected the books of account and, treating the assessee as an entry operator, estimated commission income

Rekha Manish Kapadia, Mumbai vs. ACIT-CC-8(2), Mumbai

In the result, all the appeals for AY 2014-15 are allowed partly

ITA 283/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Nov 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

Section 132Section 142(1)Section 143(2)Section 145(3)Section 153ASection 68

assessment, the Assessing Officer held that the transactions recorded by the assessee represented accommodation entries in respect of bogus purchases and sales. Invoking section 145(3) of the Act, he rejected the books of account and, treating the assessee as an entry operator, estimated commission income ... findings, the Ld. CIT(A) held that the books of account maintained by the assessee were unreliable and had been rightly rejected under section 145(3) of the Act. 4.6 Regarding the turnover disclosed by the assessee, the Ld. CIT(A) noted that although only part of the sales pertained

Rekha Manish Kapadia, Mumbai vs. ACIT CC 8(2), Mumbai

In the result, all the appeals for AY 2014-15 are allowed partly

ITA 282/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Nov 2025AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: NoneFor Respondent: Mr. Uma Shankar Prasad, CIT-DR
Section 132Section 145(3)Section 153ASection 68

assessment, the Assessing Officer held that the transactions recorded by the assessee represented accommodation entries in respect of bogus purchases and sales. Invoking section 145(3) of the Act, he rejected the books of account and, treating the Manish Kantilal Kapadia & Rekha Manish Kapadia ... findings, the Ld. CIT(A) held that the books of account maintained by the assessee were unreliable and had been rightly rejected under section 145(3) of the Act. 4.6 Regarding the turnover disclosed by the assessee, the Ld. CIT(A) noted that although only part of the sales pertained

Rekha Manish Kapadia, Mumbai vs. ACIT-CC-8(2), Mumba

In the result, all the appeals for AY 2014-15 are allowed partly

ITA 281/MUM/2025[2016-17]Status: DisposedITAT Mumbai26 Nov 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: NoneFor Respondent: Mr. Uma Shankar Prasad, CIT-DR
Section 132Section 145(3)Section 153ASection 68

assessment, the Assessing Officer held that the transactions recorded by the assessee represented accommodation entries in respect of bogus purchases and sales. Invoking section 145(3) of the Act, he rejected the books of account and, treating the Manish Kantilal Kapadia & Rekha Manish Kapadia ... findings, the Ld. CIT(A) held that the books of account maintained by the assessee were unreliable and had been rightly rejected under section 145(3) of the Act. 4.6 Regarding the turnover disclosed by the assessee, the Ld. CIT(A) noted that although only part of the sales pertained

Rekha Manish Kapadia, Mumbai vs. ACIT-CC-8(2), Mumbai

In the result, all the appeals for AY 2014-15 are allowed partly

ITA 280/MUM/2025[2015-16]Status: DisposedITAT Mumbai26 Nov 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: NoneFor Respondent: Mr. Uma Shankar Prasad, CIT-DR
Section 132Section 145(3)Section 153ASection 68

assessment, the Assessing Officer held that the transactions recorded by the assessee represented accommodation entries in respect of bogus purchases and sales. Invoking section 145(3) of the Act, he rejected the books of account and, treating the Manish Kantilal Kapadia & Rekha Manish Kapadia ... findings, the Ld. CIT(A) held that the books of account maintained by the assessee were unreliable and had been rightly rejected under section 145(3) of the Act. 4.6 Regarding the turnover disclosed by the assessee, the Ld. CIT(A) noted that although only part of the sales pertained

Manish Kantilal Kapadia, Mumbai vs. DCIT CC -8(2), Mumbai

In the result, all the appeals

ITA 264/MUM/2025[2014-15]Status: DisposedITAT Mumbai26 Nov 2025AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: NoneFor Respondent: Mr. Uma Shankar Prasad, CIT-DR

sales. Invoking section entries in respect of bogus purchases and sales. Invoking section entries in respect of bogus purchases and sales. Invoking section 145(3) of the Act, he rejected the books of account and, treating the e rejected the books of account and, treating the e rejected the books ... held that the books of account maintained by the assessee were unreliable and had been rightly unreliable and had been rightly rejected under section 145(3) of the rejected under section 145(3) of the Act. 4.6 Regarding the turnover disclosed by the assessee, the Ld. Regarding the turnover disclosed

Rekha Manish Kapadia, Mumbai vs. ACIT-CC-8(2), Mumbai

In the result, all the appeals for AY 2014-15 are allowed partly

ITA 263/MUM/2025[2014-15]Status: DisposedITAT Mumbai26 Nov 2025AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: NoneFor Respondent: Mr. Uma Shankar Prasad, CIT-DR
Section 132Section 142(1)Section 143(2)Section 145(3)Section 153ASection 68

assessment, the Assessing Officer held that the transactions recorded by the assessee represented accommodation entries in respect of bogus purchases and sales. Invoking section 145(3) of the Act, he rejected the books of account and, treating the assessee as an entry operator, estimated commission income ... findings, the Ld. CIT(A) held that the books of account maintained by the assessee were unreliable and had been rightly rejected under section 145(3) of the Act. 4.6 Regarding the turnover disclosed by the assessee, the Ld. CIT(A) noted that although only part of the sales pertained

Mohd. Sharfuddin, Moradabad vs. ITO 1(1), Moradabad

In the result, appeal of assessee in ITA No

ITA 4909/DEL/2025[2017-18]Status: DisposedITAT Delhi26 Nov 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Shri Mayank Patawari, AdvFor Respondent: Shri Om Prakash, Sr. DR
Section 144Section 145(3)Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘C’ BENCH, NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER, AND SHRI NAVEEN

Rani Devi, Patna vs. Income Tax Officer, Patna

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

ITA 308/PAT/2025[2017-18]Status: DisposedITAT Patna25 Nov 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 145(3)Section 250Section 44ASection 69ASection 80C

IN THE INCOME TAX APPELLATE TRIBUNAL, KOLKATA-PATNA ‘e-COURT’, KOLKATA [Hybrid Court Hearing] Before SHRI SONJOY SARMA, JUDICIAL MEMBER

Income Tax Officer, Ward-1(3), Ludhiana vs. Shree Balaji Processors, Ludhiana

The appeal stands dismissed

ITA 797/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh24 Nov 2025AY 2016-17

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No. 797/Chandi/2023 (िनधा"रण वष" / Assessment Year: 2016-17) Ito Ward 1(3) Shree Balaji Processors बनाम/ Ludhiana – 141001 Tajpur Road, Opp. Central Jail Vs. Ludhiana - 141010 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Actfs-8428-B (अपीलाथ"/Appellant) (""थ" / Respondent) : Assessee By : Shri Sudhir Sehgal (Advocate) - Ld. Ar Revenue By : Shri Bharat Bhushan Garg (Cit) – Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 11-11-2025 घोषणाकीतारीख /Date Of Pronouncement : 24/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Revenue For Assessment Year (Ay) 2016-17 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac, Delhi [Cit(A)] Dated 18-10-2023 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) Of The Act On 23-12-2018 Rejecting Books Of The Assessee & Assessing Business Profit Of Rs.12.81 Crores. The Ld. Cit(A) Reversed The Action Of Ld. Ao Against Which The Revenue Is In Further Appeal Before Us With Following Grounds Of Appeal: - 1. That The Cit(A), Ludhiana Has Erred In Law, In Deleting Addition Of Rs.12,01,85,191/- Made By The Assessing Officer On Account Of Rejecting The Books Of Accounts U/S 145(3) Of The Act.

For Appellant: Shri Sudhir Sehgal (Advocate) - Ld. ARFor Respondent: Shri Bharat Bhushan Garg (CIT) – Ld. DR (Virtual)
Section 142(1)Section 143(3)Section 145(3)

1 IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, CHANDIGARH HYBRID HEARING BEFORE HON’BLE SHRI RAJPAL YADAV, VICE PRESIDENT

Ram Ratan Singh Pal, Lucknow vs. Assessing Officer, NFAC, Delhi

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

ITA 387/LKW/2025[2020-21]Status: DisposedITAT Lucknow21 Nov 2025AY 2020-21

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2020-21 Ram Ratan Singh Pal V. The Assessment Unit 5C/111, Girdhar Kunj Nfac Sector 5, Vrindavan Colony Telibagh, Lucknow (U.P) Tan/Pan:Ahqpp7018N (Appellant) (Respondent) Appellant By: Ms. Gurneet Kaur, Advocate Respondent By: Shri Amit Kumar, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 18.01.2024, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2020-21. 2.0 The Brief Facts Of The Case Are That The Assessee Filed His Return Of Income For The Year Under Consideration On 15.01.2021, Declaring A Total Income Of Rs.2,81,520/- Under The Head Income From Salary. The Return Filed By The Assessee Was Processed Under Section 143(1) Of The Income Tax Act, 1961 & A Refund Of Rs.2,50,510/- Was Created. Subsequently, The Assessee Filed Revised Return Of Income Under Section 139(5) Of The Act On 25.02.2021, Declaring The Same Income Originally Returned, I.E., Rs.2,81,520/-. In The Revised Return Of Income, The Assessee Declared Income From Salary At Rs.2,81,520/- & Income From

For Appellant: Ms. Gurneet Kaur, AdvocateFor Respondent: Shri Amit Kumar, D.R
Section 139(5)Section 143(1)Section 144Section 145(3)Section 270ASection 44A

facts and figures mentioned in the books of account of the assessee were furnished, the AO rejected the books of account under section 145(3) of the Act and proceeded to calculate the income of the assessee from business/profession under section 144 of the Act on the basis of material ... without considering the facts and in the circumstances of the case, the learned assessing authority erred in law and on facts in invoking section 145(3) of the Income Tax Act, 1961 and rejecting the regularly maintained books of accounts of the assessee. ITA No.387/LKW/2025 Page

Assistant Commissioner of Income Tax, Central Circle-3(1), Kolkata vs. Rajshri Iron Industries Private Limited, Kolkata

In the result, both the appeals of the Revenue are dismissed

ITA 2388/KOL/2024[2013]Status: DisposedITAT Kolkata21 Nov 2025

Bench: Shri Rajesh Kumar, Am & Shrisonjoy Sarma, Jm

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: S/Shri Praveen Kishore &
Section 147Section 148Section 148ASection 69C

IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRISONJOY SARMA, JM ITA Nos.2385

Assistant Commissioner of Income Tax, Central Circle-3(1), Kolkata vs. Rajshri Iron Industries Private Limited, Kolkata

In the result, both the appeals of the Revenue are dismissed

ITA 2385/KOL/2024[2018]Status: DisposedITAT Kolkata21 Nov 2025

Bench: Shri Rajesh Kumar, Am & Shrisonjoy Sarma, Jm

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: S/Shri Praveen Kishore &
Section 147Section 148Section 148ASection 69C

IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRISONJOY SARMA, JM ITA Nos.2385

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Southern Agrifurane Industries Private Limited, Chennai

ITA 1819/CHNY/2025[2022-23]Status: DisposedITAT Chennai21 Nov 2025AY 2022-23

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita Nos.1817 To 1819/Chny/2025 निर्धारण वर्ष/Assessment Years: 2020-21 To 2022-23

Section 132Section 139Section 143(2)Section 143(3)Section 153CSection 250

आयकर अपीलीय अधिकरण, 'सी' न्यायपीठ,चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH: CHENNΑΙ श्री एबी टी. वर्की, न्यायिक

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Southern Agrifurane Industries Private Limited, Chennai

ITA 1818/CHNY/2025[2021-22]Status: DisposedITAT Chennai21 Nov 2025AY 2021-22

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita Nos.1817 To 1819/Chny/2025 निर्धारण वर्ष/Assessment Years: 2020-21 To 2022-23 The Dcit, Central Circle-2(2), Chennai. V. M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. (अपीलार्थी/Appellant) [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita Nos.1550 To 1552/Chny/2025 निर्धारणवर्ष/Assessment Years: 2020-21 To 2022-23 M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai – 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख / Date Of Pronouncement : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025 ::2 ::

Section 132Section 139Section 143(2)Section 143(3)Section 153CSection 250

आयकर अपीलीय अधिकरण, 'सी' न्यायपीठ,चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH: CHENNΑΙ श्री एबी टी. वर्की, न्यायिक

Southern Agrifurane Industries Pvt. Ltd., Chennai vs. ACIT, Central Circle-2(2), Chennai

ITA 1552/CHNY/2025[2022-23]Status: DisposedITAT Chennai21 Nov 2025AY 2022-23

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita Nos.1817 To 1819/Chny/2025 निर्धारण वर्ष/Assessment Years: 2020-21 To 2022-23 The Dcit, Central Circle-2(2), Chennai. V. M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. (अपीलार्थी/Appellant) [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita Nos.1550 To 1552/Chny/2025 निर्धारण वर्ष/Assessment Years: 2020-21 To 2022-23 M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai – 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख / Date Of Pronouncement V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025 ::2 ::

Section 132Section 139Section 143(2)Section 143(3)Section 153CSection 250

आयकर अपीलीय अधिकरण, 'सी' न्यायपीठ,चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH: CHENNΑΙ श्री एबी टी. वर्की, न्यायिक

Southern Agrifurane Industries Pvt. Ltd., Chennai vs. ACIT, Central Circle-2(2), Chennai

In the result, both the appeals filed by the Revenue and the

ITA 1551/CHNY/2025[2021-22]Status: DisposedITAT Chennai21 Nov 2025AY 2021-22

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Mrs. C. Yamuna, CIT &
Section 132Section 139Section 143(2)Section 143(3)Section 153CSection 250

claim that the books do not reflect true income. Therefore, the books of accounts in this case should indeed be rejected under Section 145(3) for the following reasons: » Inconsistent accounting treatments, such as the use of incorrect offset accounts for bogus transactions. >» Handling of SAP entries to process invoices ... accounts cannot be considered reliable for determining the true taxable income for the relevant assessment years. Therefore, as per the provisions of section 145(3) of the Act, the undersigned has the authority to reject these books of accounts and determine the taxable income to ascertain the true taxable income

Southern Agrifurane Industries Pvt. Ltd., Chennai vs. ACIT, Central Circle-2(2), Chennai

ITA 1550/CHNY/2025[2020-21]Status: DisposedITAT Chennai21 Nov 2025AY 2020-21

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita Nos.1817 To 1819/Chny/2025 निर्धारण वर्ष/Assessment Years: 2020-21 To 2022-23 The Dcit, Central Circle-2(2), Chennai. V. M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. (अपीलार्थी/Appellant) [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita Nos.1550 To 1552/Chny/2025 निर्धारणवर्ष/Assessment Years: 2020-21 To 2022-23 M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai – 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख / Date Of Pronouncement V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025 ::2 ::

Section 132Section 139Section 143(2)Section 143(3)Section 153CSection 250

आयकर अपीलीय अधिकरण, 'सी' न्यायपीठ,चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH: CHENNΑΙ श्री एबी टी. वर्की, न्यायिक