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...
Profit estimation on unrecorded ready-mix concrete sales must have a reasonable nexus to the material and cannot replace an accepted turnover working without supporting evidence. Where audited results for the same activity showed a gross loss and the books were neither rejected nor found defective, departing from the year-specific approach adopted in prior assessments was unsupported; the estimated gross-profit addition was deleted. Cash-credit provisions require a credit in the taxpayer's own books. Off-book pen-drive entries attributed to unrecorded sales could not support a cash-credit addition, particularly where taxing full receipts beyond their profit element would result in double assessment. The cash-credit addition was deleted.
Profit estimation on unrecorded ready-mix concrete sales must have a reasonable nexus to the material and cannot replace an accepted turnover working without supporting evidence. Where audited results for the same activity showed a gross loss and the books were neither rejected nor found defective, departing from the year-specific approach adopted in prior assessments was unsupported; the estimated gross-profit addition was deleted. Cash-credit provisions require a credit in the taxpayer's own books. Off-book pen-drive entries attributed to unrecorded sales could not support a cash-credit addition, particularly where taxing full receipts beyond their profit element would result in double assessment. The cash-credit addition was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
