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NOTE:
The ITAT upheld the CIT(A)'s rejection of the assessee's books of account u/s 145(3) as inaccurate, unreliable, and incapable of reflecting true financial affairs. It concurred with CIT(A)'s estimation of profit based on average net profit earned on regular receipts, deeming the methodology logical. Separate additions u/ss 37(1) and 40A(3) were rightly deleted once books were rejected and income estimated on gross receipts, relying on Madras HC's decision in CIT v. Amman Steel. For AY 2021-22, granting telescoping benefit against cash seized was justified as the assessee offered substantial additional income for prior years exceeding seized cash.