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...
Natural justice is not breached where the taxpayer receives repeated opportunities, issue-specific show-cause notices, and consideration of replies and evidence; the challenge to assessment validity therefore failed. Cash deposits require credible proof of source and a transaction-specific cash trail; unsupported deposits were treated as unexplained money. Consideration for land-facilitation work was characterised as business income because the land was not established as a capital asset and no refundable obligation was proved. GST-reported sales omitted from the revised income-tax return were treated as undisclosed business receipts absent cogent rebuttal. The contested additions and assessment were sustained.
Natural justice is not breached where the taxpayer receives repeated opportunities, issue-specific show-cause notices, and consideration of replies and evidence; the challenge to assessment validity therefore failed. Cash deposits require credible proof of source and a transaction-specific cash trail; unsupported deposits were treated as unexplained money. Consideration for land-facilitation work was characterised as business income because the land was not established as a capital asset and no refundable obligation was proved. GST-reported sales omitted from the revised income-tax return were treated as undisclosed business receipts absent cogent rebuttal. The contested additions and assessment were sustained.
Note: It is a system-generated summary and is for quick reference only.