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2020 (3) TMI 468 - AT - Income TaxRejection of books of accounts - invoking section 145 - NP estimation - HELD THAT:- We find the AO in the instant case, invoking the provisions of section 145 of the IT Act, rejected the book results and estimated net profit at ₹ 8,58,68,992/- by adopting net profit rate 2.77% and thereafter made addition of ₹ 3,37,59,.400/- declared by the assessee as its additional income. We find the Ld. CIT(A) deleted the addition of ₹ 8,58,68,992/- determined by the AO by estimating the net profit at ₹ 2.77% over and above the profit declared by the assessee, the reasons of which have already been reproduced in the preceding paragraph. We find identical issue had come up before the Tribunal in the case of the sister concern of the assessee namely M/s. Pearl Bottling Private Limited [2019 (2) TMI 1811 - ITAT DELHI] held his is not a fit / case for rejection of books of account and estimation of profits as the search has not thrown up any specific discrepancies in the accounts regularly maintained by the appellant. A.O. has rejected the books of account and estimated the profits of the business only based upon NP ratio without confronting the same to the appellant. This is completely in violation of principles of natural justice. A.O. has adopted a very simplistic approach in completing the assessment. - Decided against revenue.
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