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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Uncorroborated statements recorded during a survey cannot alone support an addition for estimated income as unexplained money where no unrecorded money or specified valuable article is found, audited books are not shown incorrect, and no incriminating material exists. The addition was deleted. Delayed electronic furnishing of a tax audit report may constitute reasonable cause when accounts were audited and the report signed within time, but uploading was omitted due to the auditor's illness, without intent to evade tax. The related penalty was deleted.
Uncorroborated statements recorded during a survey cannot alone support an addition for estimated income as unexplained money where no unrecorded money or specified valuable article is found, audited books are not shown incorrect, and no incriminating material exists. The addition was deleted. Delayed electronic furnishing of a tax audit report may constitute reasonable cause when accounts were audited and the report signed within time, but uploading was omitted due to the auditor's illness, without intent to evade tax. The related penalty was deleted.
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