Reassessment disclosure requirements permit stated reasons without revealing information sources, but prior-taxation claims require full examination b...
Independent assessment discretion and corroborated electronic evidence determine validity of on-money additions and undisclosed-consideration assessme...
Numerical entries in seized records may be read by appending zeros only where the interpretation is supported by the nature of the entries and surrounding material. The High Court restored the addition based on the Commissioner (Appeals)' reasoned interpretation of pages 4 and 5 of Annexure B-3, holding that the Tribunal could not append a single zero after rejecting larger multipliers without reasons. Additions for unexplained investment and undisclosed profit from other rough-diamond entries were deleted because those transactions had already been considered for taxation in another entity's assessment and the assessee lacked financial capacity to conduct the business independently. Revenue appeals were partly allowed.
Numerical entries in seized records may be read by appending zeros only where the interpretation is supported by the nature of the entries and surrounding material. The High Court restored the addition based on the Commissioner (Appeals)' reasoned interpretation of pages 4 and 5 of Annexure B-3, holding that the Tribunal could not append a single zero after rejecting larger multipliers without reasons. Additions for unexplained investment and undisclosed profit from other rough-diamond entries were deleted because those transactions had already been considered for taxation in another entity's assessment and the assessee lacked financial capacity to conduct the business independently. Revenue appeals were partly allowed.
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