https://www.taxtmi.com/caselaws?id=774120 HC held that AO cannot invoke Section 145(3) of IT Act without expressly noticing infirmities in assessee's books of accounts. Assessment based on 10% net profit rate without identifying specific defects constituted pure guesswork and violated principles established in Dhakeswari Cotton Mills. Court confirmed res judicata does not apply to tax assessments, with each year's assessment being independent. CIT (Appeals) and ITAT correctly interfered with AO's order as best judgment assessment under Section 144 was improperly applied without proper basis. Substantial question of law decided in favor of assessee against Revenue. en-us Fri, 27 Jun 2025 00:00:00 +0530 Thu, 03 Jul 2025 08:34:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774120 HC held that AO cannot invoke Section 145(3) of IT Act without expressly noticing infirmities in assessee's books of accounts. Assessment based on 10% net profit rate without identifying specific defects constituted pure guesswork and violated principles established in Dhakeswari Cotton Mills. Court confirmed res judicata does not apply to tax assessments, with each year's assessment being independent. CIT (Appeals) and ITAT correctly interfered with AO's order as best judgment assessment under Section 144 was improperly applied without proper basis. Substantial question of law decided in favor of assessee against Revenue. Case-Laws Income Tax Fri, 27 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774120