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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.
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.
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