2026 (3) TMI 1670 - SCH - Income Tax

Estimated production yield cannot justify addition without evidence; dismissal leaves the High Court's anti-guesswork approach intact.

Assessment based on estimated production yield cannot rest on bare suspicion or pure guesswork unsupported by evidence. In this matter, the High Court ... Unaccounted sales based on an estimated production yield of 89% in the Steel Melting Shop (SMS) Division of the assessee - suspicion or guesswork - rejection of books of accounts - HC [2025 (9) TMI 1771 - CHHATTISGARH HIGH COURT] held while making an assessment on estimation, the Assessing Officer cannot proceed on bare suspicion or pure guesswork unsupported by evidence. There was complete absence of adverse material to support the allegation of suppressed production, that no defect or irregularity in the books had been established, and that the addition had been founded only on an assumed industry yield carried over from earlier proceedings HELD THAT:- Special Leave Petition was dismissed as the Court was not inclined to interfere with the impugned judgment/order(s). Outcome: Special Leave Petition dismissed on the ground of delay.