2026 (5) TMI 412

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....sing the following grounds of appeal: "1. For that the Order of the Ld. CIT(A), NFAC, confirming partly the order of the Ld. ITO is arbitrary and bad in fact and in law. 2. For that the Ld. Appellate Authority, in consideration of the facts and circumstances of the matter, is not justified in sustaining addition of Rs. 23,50,313/- made by the Ld. AO on estimated basis @ 8% on gross turnover. 3. For that the Ld. Appellate Authority, in consideration of the facts and circumstances of the matter, erred in sustaining the addition made by the A.O. without rejecting the audited books of accounts maintained by the appellant. 4. For that the appellant reserves his right to add to, to alter, and or to amend the gr....

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....nal. 5. Rival contentions were heard and the submissions made have been examined. Our attention was drawn by the Ld. AR to page 2 of the assessment order in which the profit has been estimated. It was stated that the turnover was Rs.3,50,68,790/- and the net profit @8% was estimated, which was sustained by the Ld. Addl/JCIT(A). It was further stated that the appeal was filed on 07.01.2020 while the order was issued on 23.09.2025 i.e. after more than 5 years of filing of the appeal. It was stated that in the business of trading of agricultural products, the profit was uncertain. The Ld. AR was fair enough to admit that the books of account and cash book were not filed before the Ld. AO. The assessee is stated to be 45 years old and in the....