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The ITAT upheld the CIT(A)'s decision to reject the assessee's books of accounts under section 145 and estimate income under section 144. The Tribunal clarified that when income is estimated through best judgment assessment, such estimate substitutes the business income computation under sections 30-43D as prescribed by section 29. All deductions referenced in sections 30-43D are deemed incorporated within this estimate. The Tribunal rejected the Revenue's plea, finding no infirmity in the CIT(A)'s approach of rejecting the books and estimating total income based on best judgment assessment principles.
The ITAT upheld the CIT(A)'s decision to reject the assessee's books of accounts under section 145 and estimate income under section 144. The Tribunal clarified that when income is estimated through best judgment assessment, such estimate substitutes the business income computation under sections 30-43D as prescribed by section 29. All deductions referenced in sections 30-43D are deemed incorporated within this estimate. The Tribunal rejected the Revenue's plea, finding no infirmity in the CIT(A)'s approach of rejecting the books and estimating total income based on best judgment assessment principles.
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