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Whether the ITAT was correct in law in confirming the order passed by the CIT (Appeals) holding that the provisions of Section 145(3) were not applicable completely ignoring the fact that the Assessing Officer has rejected the account books of the assessee?

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Section 132, 144 & 145 of the Income Tax Act, 1961 — Accounts — Rejection of books of account— Assessing Officer had rightly rejected the books of account of both the assessees and the additions made by him were to be restored as the conclusion drawn by the AO that there was no silver at all and the story of purchase and sale of silver was entirely concocted was based on the evidence before him and the satisfaction recorded by the AO that the books of account maintained by each assessee deserved to be rejected was not perverse — Commissioner of income tax vs. Rajiv Rajiv Gupta [2019] 416 ITR 199 (Delhi)

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