Income Estimation u/s 145(3) Invalidated Due to Lack of Substantial Evidence by Assessing Officer.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Estimation of income - alleged commission income on accommodation entry - though Section 145(3) gives discretion to the AO to make an assessment in the manner provided in Section 144, yet this discretion cannot be exercised arbitrarily - there should be any material for the basis adopted by the AO or the Tribunal and the material which is irrelevant or which amounts to mere guesswork or conjecture is no material - addition deleted....