Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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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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