Held that where the books of account have been rejected, the appropriate course of action for the Assessing Officer is to estimate the gross profit in the hands of the assessee on some reasonable basis and in this regard, past history provides a reliable and reasonable basis for estimating gross profit in the hands of the assessee.The average gross profit for the past two assessment years as available on record was 25.18 per cent. as against 24.80 per cent. declared by the assessee. Therefore, the addition to the extent of differential of 0.38 per cent. was to be sustained and the remaining addition sustained by the Commissioner (Appeals) was to be deleted. Followed ACIT v. Allied Gems Corporation (I.T.A. Nos. 794 and 795/JP/2011 and 716/JP/2012, dated December 15, 2017). (AY. 2012-13)