Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
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 4891 
