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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Genuineness of agricultural receipts requires evidence of actual cultivation, including land details, crops and plantations, irrigation facilities, labour, horticultural borrowings and supporting photographs. Where such material establishes extensive agricultural operations, the reasonableness of net agricultural income must be assessed after accounting for disclosed cultivation expenditure and the scale of activity. Treating full gross agricultural receipts as income without allowing cultivation costs disregards the distinction between gross receipts and net income. Absence of cash deposits or unexplained investments may further support the stated agricultural source.
Genuineness of agricultural receipts requires evidence of actual cultivation, including land details, crops and plantations, irrigation facilities, labour, horticultural borrowings and supporting photographs. Where such material establishes extensive agricultural operations, the reasonableness of net agricultural income must be assessed after accounting for disclosed cultivation expenditure and the scale of activity. Treating full gross agricultural receipts as income without allowing cultivation costs disregards the distinction between gross receipts and net income. Absence of cash deposits or unexplained investments may further support the stated agricultural source.
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