ITAT Rules: Income Determination Based on Surmise and Conjecture is Illegal

DCIT Vs Vinod Kumar Bajaj (ITAT Delhi) Introduction: The Income Tax Appellate Tribunal (ITAT) of Delhi recently issued a significant ruling in the case of DCIT Vs Vinod Kumar Bajaj, where it declared the act of determining income based purely on conjecture and presumption as grossly illegal. The case revolved around an addition made to Bajaj’s income by the Assessing Officer (AO) based on an internal email conversation, which the AO considered as evidence of undisclosed income from election consultancy services. Analysis: In this case, the AO presumed that Bajaj had provided election con...