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    <title>Addition based on assumed low yield set aside; AO failed to connect calculated consumption with alleged unaccounted production under s.145(3) (3)</title>
    <link>https://www.taxtmi.com/highlights?id=92007</link>
    <description>The HC upheld the concurrent findings of the CIT(A) and ITAT that the AO failed to establish a probative nexus between calculated consumption figures and the presumed suppressed yield; therefore the AO&#039;s addition for alleged unaccounted production and sales was arbitrary and speculative. Both appellate authorities, after objective appraisal of the evidentiary material, found no adverse material to impeach the assessee&#039;s books or to justify rejection of accounts under s.145(3). In consequence, the addition premised on assumed low yield was set aside and the Revenue&#039;s appeal dismissed, the courts treating the AO&#039;s exercise as conjectural rather than evidential.</description>
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    <pubDate>Thu, 28 Aug 2025 08:32:48 +0530</pubDate>
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      <title>Addition based on assumed low yield set aside; AO failed to connect calculated consumption with alleged unaccounted production under s.145(3) (3)</title>
      <link>https://www.taxtmi.com/highlights?id=92007</link>
      <description>The HC upheld the concurrent findings of the CIT(A) and ITAT that the AO failed to establish a probative nexus between calculated consumption figures and the presumed suppressed yield; therefore the AO&#039;s addition for alleged unaccounted production and sales was arbitrary and speculative. Both appellate authorities, after objective appraisal of the evidentiary material, found no adverse material to impeach the assessee&#039;s books or to justify rejection of accounts under s.145(3). In consequence, the addition premised on assumed low yield was set aside and the Revenue&#039;s appeal dismissed, the courts treating the AO&#039;s exercise as conjectural rather than evidential.</description>
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      <pubDate>Thu, 28 Aug 2025 08:32:48 +0530</pubDate>
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