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HC upheld the concurrent findings of CIT(A) and ITAT that the Assessing Officer's addition under Section 145(3) for alleged suppression of production/yield was unsupported by tangible evidence and predicated on mere conjecture, thereby invalidating the rejection of books of account. Applying established principles regarding evaluation of accounts and estimation, the court held the authorities correctly recorded a factual conclusion that the declared yield was not implausibly low and that no adverse material existed to impeach the assessee's records. The HC found the concurrent factual conclusion neither perverse nor contrary to record and dismissed Revenue's appeal, confirming the ITAT's order in favour of the assessee.
HC upheld the concurrent findings of CIT(A) and ITAT that the Assessing Officer's addition under Section 145(3) for alleged suppression of production/yield was unsupported by tangible evidence and predicated on mere conjecture, thereby invalidating the rejection of books of account. Applying established principles regarding evaluation of accounts and estimation, the court held the authorities correctly recorded a factual conclusion that the declared yield was not implausibly low and that no adverse material existed to impeach the assessee's records. The HC found the concurrent factual conclusion neither perverse nor contrary to record and dismissed Revenue's appeal, confirming the ITAT's order in favour of the assessee.
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