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Cash-method accounting precludes taxation of notional interest,...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and verification.
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Cash-method accounting precludes taxation of notional interest, dividend or interest income unless actual receipt is established; rejection of books does not by itself justify mercantile or presumptive assessment. Ready-forward securities transactions are treated in substance as short-term lending and do not necessarily generate share-trading profit. Negative opening stock, undelivered securities transactions, brokered trades and prior-year advances cannot be treated as unexplained investment for the relevant year without supporting material. Unexplained bank credits remain taxable where their nature and source are not satisfactorily explained. Appellate enhancement requires opportunity, while disclosed-source claims may require verification. Telescoping against assessed income, statutory deductions and tax credit require consequential application; interest on a fresh demand after de novo assessment runs from default under that fresh demand.
Cash-method accounting precludes taxation of notional interest, dividend or interest income unless actual receipt is established; rejection of books does not by itself justify mercantile or presumptive assessment. Ready-forward securities transactions are treated in substance as short-term lending and do not necessarily generate share-trading profit. Negative opening stock, undelivered securities transactions, brokered trades and prior-year advances cannot be treated as unexplained investment for the relevant year without supporting material. Unexplained bank credits remain taxable where their nature and source are not satisfactorily explained. Appellate enhancement requires opportunity, while disclosed-source claims may require verification. Telescoping against assessed income, statutory deductions and tax credit require consequential application; interest on a fresh demand after de novo assessment runs from default under that fresh demand.
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