R. H. Agro Overseas P. Ltd. v. Asst. CIT (2025) 127 ITR 37 / 180 taxmann.com 92 (Delhi)(Trib.)

S. 145 : Method of accounting Rejection of books of account-Failure to produce records due to factory seizure-Estimation of gross profit-Reduction by Commissioner (Appeals) upheld-Assessing Officer doubting only trading results-No defect found in manufacturing segment-Overall rejection of books unjustified.[S. 145(3)]

For the assessment year 2014-15, the assessee failed to produce supporting records as its factory had been seized by banks. The Assessing Officer rejected the books of account and estimated gross profit. The Commissioner (Appeals) substantially reduced the addition after considering the losses suffered due to industry recession, export rejections and closure of the factory. The Tribunal held that the assessee had failed to challenge the rejection of books or produce evidence before the Assessing Officer and found no reason to interfere with the reduced addition sustained by the Commissioner (Appeals).  For the assessment year 2013-14, the Assessing Officer doubted only the losses from the trading segment but proceeded to reject the entire books of account and estimate gross profit for the whole business. The Tribunal held that, in the absence of any defect in the manufacturing segment, rejection of the entire books was unwarranted, and there was no basis for estimating overall gross profit. The order of the Commissioner (Appeals) deleting the addition was upheld.  (AY. 2013-14, 2014-15).

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