Third-party search material requires special assessment route, rendering general reassessment notices without jurisdiction when it forms the proceedin...
Transfer-pricing adjustments must be confined to international associated-enterprise transactions, while functionally dissimilar comparables remain ex...
Insolvency moratorium bars income-tax revision proceedings against corporate debtors until the moratorium ends, preserving merits for later determinat...
Suppressed turnover arising from unrecorded sales generated in a disclosed business is assessable only to the embedded profit, absent evidence of unexplained investment or an independent undisclosed activity. Because gross receipts recover both cost and profit, historical profitability provides an objective estimation basis; a moderately higher margin may apply to incremental out-of-books realisation. Profit was estimated at 2%, restricting the turnover addition to that amount; the evidentiary value of individual Excel sheets remained undecided. Cash-payment disallowance requires payment-wise, person-wise and day-wise verification against the prescribed limit, rather than yearly ledger aggregates. Claimed Rule 6DD exceptions require supporting-material verification, and the disallowance was remanded for that limited examination.
Suppressed turnover arising from unrecorded sales generated in a disclosed business is assessable only to the embedded profit, absent evidence of unexplained investment or an independent undisclosed activity. Because gross receipts recover both cost and profit, historical profitability provides an objective estimation basis; a moderately higher margin may apply to incremental out-of-books realisation. Profit was estimated at 2%, restricting the turnover addition to that amount; the evidentiary value of individual Excel sheets remained undecided. Cash-payment disallowance requires payment-wise, person-wise and day-wise verification against the prescribed limit, rather than yearly ledger aggregates. Claimed Rule 6DD exceptions require supporting-material verification, and the disallowance was remanded for that limited examination.
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