Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
A bank stock statement cannot alone establish undervaluation of closing stock for tax purposes without independently verified evidence. Where the taxpayer consistently applied its valuation method, reconciled differences from bank figures, and the books showed no defects, deletion of the addition was upheld. Applying the principle of consistency, deletion of interest disallowance on unpaid purchase price was sustained because no distinguishing facts or evidence of related-party payment or unreasonable interest emerged. Deletion of Keyman Insurance Policy premium disallowance was also upheld, as the company was the policy beneficiary and earlier-year treatment was followed. The tax appeal was dismissed for absence of a substantial question of law.
A bank stock statement cannot alone establish undervaluation of closing stock for tax purposes without independently verified evidence. Where the taxpayer consistently applied its valuation method, reconciled differences from bank figures, and the books showed no defects, deletion of the addition was upheld. Applying the principle of consistency, deletion of interest disallowance on unpaid purchase price was sustained because no distinguishing facts or evidence of related-party payment or unreasonable interest emerged. Deletion of Keyman Insurance Policy premium disallowance was also upheld, as the company was the policy beneficiary and earlier-year treatment was followed. The tax appeal was dismissed for absence of a substantial question of law.
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