Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Reassessment based on search-related information may be initiated under reassessment provisions where the Assessing Officer also relies on independent enquiries into transactions with an alleged entry provider, rather than on search material alone. Approval for the reassessment notice was treated as procedurally valid and non-mechanical, and the challenge to reassessment failed. Where sales are accepted but purchases from an alleged accommodation-entry provider remain unverifiable, the entire purchase amount need not be disallowed, particularly where the relied-on statement was retracted. The addition was confined to the profit element reflected in the taxpayer's gross-profit position, fixed at 6% of the disputed purchases. The appeal was partly allowed on the quantum of addition.
Reassessment based on search-related information may be initiated under reassessment provisions where the Assessing Officer also relies on independent enquiries into transactions with an alleged entry provider, rather than on search material alone. Approval for the reassessment notice was treated as procedurally valid and non-mechanical, and the challenge to reassessment failed. Where sales are accepted but purchases from an alleged accommodation-entry provider remain unverifiable, the entire purchase amount need not be disallowed, particularly where the relied-on statement was retracted. The addition was confined to the profit element reflected in the taxpayer's gross-profit position, fixed at 6% of the disputed purchases. The appeal was partly allowed on the quantum of addition.
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