COURT: | ITAT Mumbai |
CORAM: | Amarjit Singh (JM), B. R. Baskaran (AM) |
SECTION(S): | 143(3) |
GENRE: | Domestic Tax |
CATCH WORDS: | extrapolation |
COUNSEL: | Hariom Tulsyan |
DATE: | September 11, 2015 (Date of pronouncement) |
DATE: | October 12, 2015 (Date of publication) |
AY: | 2002-03 to 2008-09 |
FILE: | Click here to view full post with file download link |
CITATION: | |
Extrapolation: Fact that assessee admitted undisclosed income for one year does not mean that AO can assume that similar undisclosed income is earned in earlier years as well |
The assessing officer did not bring any material on record to support his case of estimation of professional receipts of earlier years. We also notice that the assessing offer has assessed the net profit on the alleged suppressed professional receipts, meaning thereby, the assessing officer has presumed that the assessee would have suppressed corresponding expenses also. Again it is only a guess work only, unsupported by any material. Similarly, the average daily collection estimated by the AO was also mere guess work. In effect, there is no material available with the AO to show that the assessee has suppressed professional receipts as well as expenses in order to substantiate the estimation made by him
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