Disallowance for TDS default shall be attracted even if income is estimated by AO after rejecting bo

IT : The estimation of income upon rejection of the assessee's accounts as not reliable for assessment of income u/s.145(3) is to be made transparently, in two steps. The first being toward assessment of commercial profits, and then again the specific allowances or disallowances that stand to be effected, as u/s.40(a)(ia), an artificial, statutory disallowance.