Foundational assessment satisfaction is essential before initiating penalty for cash receipt of immovable-property sale consideration under section 27...
Tax collection at source on purchases removes duplicate withholding obligation, while trade-creditor evidence requires verification before unexplained...
Transfer-pricing comparability requires material turnover effects; adjustments must cover only associated-enterprise transactions and exclude abnormal...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
