PCIT v. Mahabir Jute Mills Ltd [2024] 162 taxmann.com 601 / (2025) 482 ITR 345 (All)(HC)

S. 145 : Method of accounting-No rejection of books of account-Deletion of addition by the Tribunal based on three years’ gross profit is affirmed.[S.260A]

Held that  in the absence of any other objection found in the books of account of the assessee, there survived no room to reject the books of account of the assessee. Consequently, there was no intrinsic evidence to enhance the gross profit rate. Once the books of account of an assessee had been accepted, the Assessing Officer should have remained within the confines of his powers and not disturbed the gross profit rate, as that would remain in the nature of the result of the book entries and not an original entry by itself. It was not open to the Assessing Officer to reject the gross profit rate disclosed by the assessee. The finding on the acceptance of books of account of the assessee recorded by the Commissioner (Appeals) was not even specifically challenged. The order of the Tribunal was affirmed. (AY. 2014-15)

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