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...
Under the mercantile system of accounting, notional interest on outstanding advances was not justified where evidence showed that no interest had been received for two preceding years and the debtor concerns' financial condition had deteriorated. One concern had ceased business activity, as indicated by cancellation of its sales tax registration and application to cancel excise registration, while material concerning the other concern was not properly considered. Family relationships with the assessee's partners alone did not support imputing interest. The article records that the High Court treated the contrary findings as perverse and deleted the notional-interest addition.
Under the mercantile system of accounting, notional interest on outstanding advances was not justified where evidence showed that no interest had been received for two preceding years and the debtor concerns' financial condition had deteriorated. One concern had ceased business activity, as indicated by cancellation of its sales tax registration and application to cancel excise registration, while material concerning the other concern was not properly considered. Family relationships with the assessee's partners alone did not support imputing interest. The article records that the High Court treated the contrary findings as perverse and deleted the notional-interest addition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
