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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Rejection of books of account may be sustained where primary books, bills and vouchers are repeatedly not produced; an audit report does not replace records required for verification. Best-judgment disallowance of unverifiable expenditure must nevertheless rest on relevant material and bear a reasonable nexus to it, rather than amounting to a pure guess. Rejection of accounts alone does not justify an addition, and acceptance of recorded receipts or absence of objection to a proposed rate cannot supply evidentiary reasons. Adjacent-year audited financial statements, books and vouchers may be verified for fresh quantification after hearing.
Rejection of books of account may be sustained where primary books, bills and vouchers are repeatedly not produced; an audit report does not replace records required for verification. Best-judgment disallowance of unverifiable expenditure must nevertheless rest on relevant material and bear a reasonable nexus to it, rather than amounting to a pure guess. Rejection of accounts alone does not justify an addition, and acceptance of recorded receipts or absence of objection to a proposed rate cannot supply evidentiary reasons. Adjacent-year audited financial statements, books and vouchers may be verified for fresh quantification after hearing.
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