Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Credit-note turnover adjustments preserve inverted-duty refunds, while ministerial re-computation does not constitute an impermissible appellate reman...
Unverified sundry creditors may be examined as unexplained credits; their classification alone does not preclude an addition. Business-expenditure disallowances cannot be substantially reduced without evidence substantiating the expenditure. Appellate relief deleting the creditor addition and reducing the expenditure disallowance was set aside because the assessee sought to produce evidence for the accounting entries and its tax-exemption claim. The additions and exemption claim were remitted to the Assessing Officer for fresh factual consideration on the evidence, without a decision on merits.
Unverified sundry creditors may be examined as unexplained credits; their classification alone does not preclude an addition. Business-expenditure disallowances cannot be substantially reduced without evidence substantiating the expenditure. Appellate relief deleting the creditor addition and reducing the expenditure disallowance was set aside because the assessee sought to produce evidence for the accounting entries and its tax-exemption claim. The additions and exemption claim were remitted to the Assessing Officer for fresh factual consideration on the evidence, without a decision on merits.
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