Year-wise GST tax periods make composite show cause notices impermissible, requiring separate proceedings despite contrary non-jurisdictional preceden...
Uncorroborated third-party search material cannot support additions for alleged cash coal purchases where recorded sales, coal consumption, production and books remain accepted, and no abnormal input-output pattern or independent evidence is established. Estimated profit from hypothetical unrecorded coal sales was therefore deleted. Likewise, a retracted statement alleging under-invoicing of mill scale sales, coupled with CCTV-based presumptions, is insufficient where the cash is explained as recorded and no independent evidence confirms suppressed sales. The estimated-profit additions for alleged mill scale suppression were deleted for both assessment years, and the appeals succeeded.
Uncorroborated third-party search material cannot support additions for alleged cash coal purchases where recorded sales, coal consumption, production and books remain accepted, and no abnormal input-output pattern or independent evidence is established. Estimated profit from hypothetical unrecorded coal sales was therefore deleted. Likewise, a retracted statement alleging under-invoicing of mill scale sales, coupled with CCTV-based presumptions, is insufficient where the cash is explained as recorded and no independent evidence confirms suppressed sales. The estimated-profit additions for alleged mill scale suppression were deleted for both assessment years, and the appeals succeeded.
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TaxTMI 
TaxTMI 
