2025 (12) TMI 857

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....n law and must be quashed. 2. That having regard to the facts and circumstances of the case, Ld AO/CIT(A) has erred in law and on the facts in making addition of Rs. 1.31 crore on the basis of estimation of profit calculated @ 8 percent of Gross Receipt of Rs. 20.75 crore. The addition made by Ld. AO/CIT(A) treating them as non-genuine is arbitrary, capricious, unwarranted and must be quashed. 3. That the action of Ld. Assessing officer/CIT(A) in making addition of Rs. 1.31/- crore on account of rejection of audited books of accounts by invoking provisions of section 145(3) is erroneous. The addition so made is arbitrary, capricious, unwarranted and must be quashed. 4. That in any case and in view of the matter, t....

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....stallations, etc in connection with Trespass control at Kurla and Dadar Stations in Mumbai - LOT III amounting to Rs. 60 Cr. 5. The assessee filed its return of income declaring income of Rs. 34,95,789/- alongwith audited financial statements. The assessment was completed u/s. 143(3) of the Income-tax Act, 1961 [the Act, for short] while rejecting the books of account and an adhoc addition of Rs. 1,66,01,922 was made by estimating net profit @ 8% of gross receipts of Rs. 20,75,24,036. Relief of already declared net profit of Rs. 34,95,789 was granted and a net addition of Rs. 1,31,06,133 (Rs. 1,66,01,922 Less Rs. 34,95,789) was made. 6. Aggrieved, the assessee went in appeal before the ld. CIT(A) who dismissed the appeal of the assess....

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....until and unless any discrepancy or infirmity is detected in the books already furnished by the assessee. 9. The ld. counsel for the assessee submitted that the assessee submitted the audit report and the audited financial statement when the complete books of account were sought since complete books of accounts including all documents and invoices would have meant humongous details and the Assessing Officer did not specifically ask the assessee any specific question in the show cause notice issued and kept on asking complete books of account. Further, the Assessing Officer neither pinpointed any defect in the information submitted earlier nor sought for any further information or queries. 10. The ld. counsel for the assessee relied on....