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    <title>2025 (5) TMI 1069 - ITAT DELHI</title>
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    <description>ITAT Delhi ruled that CIT(A) was unjustified in rejecting books of accounts under section 145(3) and applying net profit rate estimation when AO had made specific disallowances for inflated purchases. The tribunal held that AO&#039;s discretionary power under section 145(3) should be exercised only when books are incorrect/incomplete or don&#039;t follow proper accounting methods. Since AO chose specific disallowances over book rejection, CIT(A) couldn&#039;t subsequently reject books on same facts. However, disallowance of unverifiable purchases was sustained as assessee failed to establish genuineness. Disallowances under sections 40(a)(ia) and 40A(3) were deleted.</description>
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    <pubDate>Wed, 09 Apr 2025 00:00:00 +0530</pubDate>
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      <title>2025 (5) TMI 1069 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=770797</link>
      <description>ITAT Delhi ruled that CIT(A) was unjustified in rejecting books of accounts under section 145(3) and applying net profit rate estimation when AO had made specific disallowances for inflated purchases. The tribunal held that AO&#039;s discretionary power under section 145(3) should be exercised only when books are incorrect/incomplete or don&#039;t follow proper accounting methods. Since AO chose specific disallowances over book rejection, CIT(A) couldn&#039;t subsequently reject books on same facts. However, disallowance of unverifiable purchases was sustained as assessee failed to establish genuineness. Disallowances under sections 40(a)(ia) and 40A(3) were deleted.</description>
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      <pubDate>Wed, 09 Apr 2025 00:00:00 +0530</pubDate>
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