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of <h1>ITAT confirms CIT(A) decisions on income estimation, book rejection, share transactions, and revenue appeal</h1> <h3>M/s. Kalpit Trading P. Ltd., M/s. Cavalier Trading P. Ltd. Versus Dy. CIT, OSD-II, Central Range-7, Mumbai</h3> M/s. Kalpit Trading P. Ltd., M/s. Cavalier Trading P. Ltd. Versus Dy. CIT, OSD-II, Central Range-7, Mumbai - TMI Issues:1. Rejection of books of account and estimation of income at 3% of aggregate purchases and sales.2. Consideration of purchase and sales bills leading to double computation of income.3. Estimation of income at 3% on transactions of shares.4. Disallowance of expenditure incurred for business purposes.5. Acceptance and disregard of director's averments.Analysis:Issue 1:The assessee challenged the rejection of books of account and income estimation at 3% of purchases and sales. The AO assessed income based on a search action revealing accommodation bills issuance without actual goods delivery. The CIT(A) reduced the estimation to 1.5%. The ITAT upheld the CIT(A)'s decision, emphasizing the absence of material to reduce it further to 1%.Issue 2:The AO considered certain purchase and sales bills twice, leading to double computation of income. The CIT(A) confirmed the addition to a certain extent. The ITAT reviewed the case, noting the absence of justifiable grounds to interfere with the CIT(A)'s decision, ruling in favor of the revenue.Issues 3 and 4:The assessee contested the confirmation of addition to the extent of 1.5% on unexplained share transactions. The CIT(A) partially allowed the appeal, reducing the estimated income to 1.5% of the transaction amount. The ITAT found no material to interfere with the CIT(A)'s finding, confirming the decision in favor of the revenue.Issue 5:The AO's estimation of income at 3% disregarding the prior year's 1% estimation was challenged. The CIT(A) upheld the AO's decision. The ITAT dismissed the appeal, considering the findings in line with the previous appeal.In conclusion, the ITAT upheld the CIT(A)'s decisions on various issues, emphasizing the lack of substantial material to alter the income estimations. The appeals filed by the assessee were dismissed, and the orders were pronounced on 29.05.2018.
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