Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Unsupported claims for expenditure against commission income cannot be accepted solely on the taxpayer's assertions. The text explains that, despite the absence of documentary evidence, the nature of commission activities, the taxpayer's age, cash withdrawals and the scale of commission receipts indicated that substantial expenditure on assistance, administrative needs and incidental items was inevitable. It considers an estimate of 10 per cent of gross commission receipts inadequate and prescribes allowance of expenditure at 20 per cent, requiring consequential recomputation of income.
Unsupported claims for expenditure against commission income cannot be accepted solely on the taxpayer's assertions. The text explains that, despite the absence of documentary evidence, the nature of commission activities, the taxpayer's age, cash withdrawals and the scale of commission receipts indicated that substantial expenditure on assistance, administrative needs and incidental items was inevitable. It considers an estimate of 10 per cent of gross commission receipts inadequate and prescribes allowance of expenditure at 20 per cent, requiring consequential recomputation of income.
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