Assessment safeguards: require specific factual foundations and procedural enquiry before making disallowances or invoking concealment penalties. Instruction identifies recurring defects in assessments - unsupported gross profit reductions, general expense disallowances, unsubstantiated directors' remuneration adjustments, cash-credit additions without proper enquiry, inadequate-drawings adjustments lacking factual support, and concealment-penalty imposition without adequate onus - and directs officers to follow prior circulars, maintain confidential registers and records, state specific facts and reasons for disallowances, observe procedural safeguards (including opportunity for cross-examination), and circulate favorable appellate precedents for guidance.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Assessment safeguards: require specific factual foundations and procedural enquiry before making disallowances or invoking concealment penalties.
Instruction identifies recurring defects in assessments - unsupported gross profit reductions, general expense disallowances, unsubstantiated directors' remuneration adjustments, cash-credit additions without proper enquiry, inadequate-drawings adjustments lacking factual support, and concealment-penalty imposition without adequate onus - and directs officers to follow prior circulars, maintain confidential registers and records, state specific facts and reasons for disallowances, observe procedural safeguards (including opportunity for cross-examination), and circulate favorable appellate precedents for guidance.
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