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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Recorded tyre sales already included in audited books and taxable profits could not also be treated as a separate source of income through an alleged cash return. Retaining the sales in the profit and loss account while assessing the alleged returned cash separately would result in double taxation, particularly where sale records, vouchers and stock records disclosed no identified defect; the cash-return addition was deleted. Commission allegedly retained for facilitating accommodation entries through those sales remained added because the assessee conceded it, without merits adjudication.
Recorded tyre sales already included in audited books and taxable profits could not also be treated as a separate source of income through an alleged cash return. Retaining the sales in the profit and loss account while assessing the alleged returned cash separately would result in double taxation, particularly where sale records, vouchers and stock records disclosed no identified defect; the cash-return addition was deleted. Commission allegedly retained for facilitating accommodation entries through those sales remained added because the assessee conceded it, without merits adjudication.
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