https://www.taxtmi.com/caselaws?id=797393 Audited books cannot be rejected under Section 145(3) merely because some persons fail to respond to third-party verification notices, absent identified defects, accounting irregularities, or material discrepancies. Where the assessee provides details of over 4,000 persons and available particulars are verified, non-compliance by selected persons alone is insufficient. Income from an HR-outsourcing business also cannot be estimated at a fixed percentage of gross receipts without separating salary and statutory reimbursements, which are pass-through costs, from actual income and establishing a rational factual basis. Rejection of books and the resulting addition were therefore unjustified. en-us Wed, 12 Aug 2026 00:00:00 +0530 Fri, 21 Aug 2026 08:28:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797393 Audited books cannot be rejected under Section 145(3) merely because some persons fail to respond to third-party verification notices, absent identified defects, accounting irregularities, or material discrepancies. Where the assessee provides details of over 4,000 persons and available particulars are verified, non-compliance by selected persons alone is insufficient. Income from an HR-outsourcing business also cannot be estimated at a fixed percentage of gross receipts without separating salary and statutory reimbursements, which are pass-through costs, from actual income and establishing a rational factual basis. Rejection of books and the resulting addition were therefore unjustified. Case-Laws Income Tax Wed, 12 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797393