Rejection of audited books requires specific accounting defects; fixed-rate profit estimation on pass-through reimbursements was rejected.

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....Rejection of audited books under section 145(3) requires specific defects in the accounts and cannot rest solely on non-compliance with sample third-party notices issued under section 133(6). Where the Assessing Officer verified the supplied particulars and the receipts of an HR outsourcing provider substantially comprised salary and statutory reimbursements as pass-through costs, treating total gross receipts as income and applying a fixed profit rate lacked a rational basis. The estimated addition was therefore arbitrary; deletion by the Commissioner (Appeals) was sustained and the Revenue's appeal was dismissed.....