PCIT v. Forum Sales (P.) Ltd. (2024) 298 Taxman 533 (Delhi)(HC)

S. 145 : Method of accounting-Books of account not rejected-Income cannot estimated without rejecting the books of account.[S. 132, 144,145(3), 153A]

Assessee is  engaged in providing corporate gifting solutions to various companies.  A search and seizure operation under section 132 was conducted upon AMQ group of companies including assessee. Assessing Officer issued a notice under section 153A to assessee. Assessing Officer made additions to income of assessee on account of estimation of unaccounted profit, disallowance of expenses and inflated purchases. CIT(A) partly allowed the disallowance. On appeal the Tribunal deleted the disallowance. On appeal the Tribunal held that since Assessing Officer made additions to income of assessee on estimate basis without rejecting books of account, said additions were to be deleted.  (AY. 2013-14 & 2014-15)