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Presumptive taxation does not permit enhancement of declared business profit merely by applying average profit margins from preceding years. Although the Assessing Officer may examine a claim under the presumptive taxation regime, any challenge must rest on adverse material. A taxpayer declaring income under that regime is not required to maintain books of account solely for that reason, and a stated decline in profit margin cannot be rejected without material disproving the explanation. The Tribunal's majority view found the adopted net-profit rate unjustified and allowed the taxpayer's appeal.
Presumptive taxation does not permit enhancement of declared business profit merely by applying average profit margins from preceding years. Although the Assessing Officer may examine a claim under the presumptive taxation regime, any challenge must rest on adverse material. A taxpayer declaring income under that regime is not required to maintain books of account solely for that reason, and a stated decline in profit margin cannot be rejected without material disproving the explanation. The Tribunal's majority view found the adopted net-profit rate unjustified and allowed the taxpayer's appeal.
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