Ad-hoc determination without invoking special audit not justifiable due to complexity of business

Virupakaxappa Sidramappa Bembalgi Vs ITO (ITAT Panaji)

ITAT Panaji held that ad-hoc determination of taxable income without invoking special audit u/s. 142(2A) of the Income Tax Act not only jostled ad-hoc & irrational estimations but led to farfetched determination due to complexity of business. Accordingly, matter remanded back to AO.

Facts- The assessee is partnership firm engaged in trading business of precious metal. The return of income filed on 20/10/2017 by the assessee declaring total income of ₹NIL was selected for scrutiny wherein the books

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