Dismissing the petition the Court held that the Assessing Officer  brought to the notice of the assessee with respect to his doubts relating to the correctness and completeness of the accounts of the assessee. The Assessing Officer had observed that since the expenditure claimed was not verifiable, income was proposed to be assessed at 12 per cent. of the total disclosed revenue after rejecting the books of account under section 145(3). Therefore, the submission that the assessee had not been apprised of the proposed rejection of books and variation in income was unsustainable. In the absence of documentary evidence, there was no other option but to complete the assessment on the basis of material available on record.   That with regard to the disallowance under section 40(a)(ia), the Assessing Officer had stated in the assessment order under section 143(3) read with section 144B that the assessee had not furnished the method of payment either by way of cash or through banking channel and copy of ledger of confirmation or any bills or vouchers on sample basis, that had made huge payments to non-GST entities and had also not furnished copy of ledger of confirmation but had only furnished the name, permanent account number, lorry number, amount and date only, that the assessee had not furnished documentary evidences in support of expenses, that the assessee had shown direct expenses, i. e., carriage inward and other expenses which was 92 per cent. of the total revenue from operation, that in such circumstances, expenses incurred by the assessee was not verifiable and could not be accepted that the expenses shown by the assessee to entities was genuine or reliable, and that since the books of account was also not reliable, the income was assessed at 12 per cent. of total revenue from operation after rejecting the books of account under section 145(3). It was manifest from the assessment order that no specific disallowance under section 40(a)(ia) nor any additions on that account had been made. All that the Assessing Officer had observed was that the disallowance was not being made at that stage subject to the view that any appellate authority would take with respect to rejection of books of account under section 145(3). Therefore, there was no merit in the challenge.  All contentions of  assessee is left open to be  raised before Appellate Authority  (AY. 2022-23)