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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Reverse burden for notified gold under section 123 arises only where tangible material supports a reasonable belief of smuggling; inland seizure or absence of foreign markings alone is insufficient. Assessment requires cumulative consideration of carriage, the article's nature, statements, documentary provenance and accounting trail. Registered suppliers and tax invoices supporting domestically acquired gold may establish lawful provenance unless shown to be false or unconnected with business stock. The claimant may discharge the burden on a preponderance of probability through reliable documents and circumstances, without proving uninterrupted physical identity of fungible gold unless circumstances warrant it.
Reverse burden for notified gold under section 123 arises only where tangible material supports a reasonable belief of smuggling; inland seizure or absence of foreign markings alone is insufficient. Assessment requires cumulative consideration of carriage, the article's nature, statements, documentary provenance and accounting trail. Registered suppliers and tax invoices supporting domestically acquired gold may establish lawful provenance unless shown to be false or unconnected with business stock. The claimant may discharge the burden on a preponderance of probability through reliable documents and circumstances, without proving uninterrupted physical identity of fungible gold unless circumstances warrant it.
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