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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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Section 144B did not apply where the assessment was made by the jurisdictional Assessing Officer outside the faceless-assessment framework and mandatory notices had been issued; procedural non-observance therefore did not invalidate the assessment. Rejection of books of account and profit estimation in online share trading require substantial accounting discrepancies and adherence to best judgment principles. Absence of matching bank credits or an adverse turnover-to-expense ratio alone was insufficient where broker-mediated pay-ins and payouts, regular accounting methods, and transactional evidence were not properly considered. Profit estimation must have a rational, business-specific basis rather than rely on guesswork; the estimated profit addition was deleted.
Section 144B did not apply where the assessment was made by the jurisdictional Assessing Officer outside the faceless-assessment framework and mandatory notices had been issued; procedural non-observance therefore did not invalidate the assessment. Rejection of books of account and profit estimation in online share trading require substantial accounting discrepancies and adherence to best judgment principles. Absence of matching bank credits or an adverse turnover-to-expense ratio alone was insufficient where broker-mediated pay-ins and payouts, regular accounting methods, and transactional evidence were not properly considered. Profit estimation must have a rational, business-specific basis rather than rely on guesswork; the estimated profit addition was deleted.
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