Held that the Commissioner (Appeals) having rejected the books of account, ought to have estimated the income of the assessee for the whole year : he could not estimate the profit merely on the alleged undisclosed sales or unproved purchases. Therefore, the addition per se of unproved purchases and unproved sales could not be made in the hands of the assessee and the question of estimation of the profit thereon did not survive. (AY. 2014-15 to 2020-21)
Bee Pee Rollers P. Ltd. v. Asst. CIT (2024) 110 ITR 402 (Cuttack) (Trib) Bajrangbali Re-Rollers P.Ltd v. Asst. CIT (2024) 110 ITR 402 (Cuttack) (Trib) Bajrangbali Steel Industries P.Ltd v. Asst. CIT (2024) 110 ITR 402 (Cuttack) (Trib)
S. 153A: Assessment-Search-Bogus purchases and sales-No evidence was found during search or in course of assessment proceedings to prove sellers and buyers bogus-Profit estimated on unproved purchases and 5 Per Cent. profit on unproved sales is held to be not proper.[S.69C]