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Accommodation-entry information supports reassessment when independently assessed, while receipts matched by sales may attract fact-specific profit taxation.
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Specific, credible information about a non-existent accommodation-entry provider can furnish tangible material for reassessment under section 147 where the recorded reasons show application of mind and the requisite approval is obtained, rather than borrowed satisfaction. A receipt squared up against sales of the same amount to the same party was taxed only to the extent of the embedded profit, fixed at 6%, with the balance deleted. This treatment was confined to the particular facts and parties' submissions and was expressly not a precedent.
Specific, credible information about a non-existent accommodation-entry provider can furnish tangible material for reassessment under section 147 where the recorded reasons show application of mind and the requisite approval is obtained, rather than borrowed satisfaction. A receipt squared up against sales of the same amount to the same party was taxed only to the extent of the embedded profit, fixed at 6%, with the balance deleted. This treatment was confined to the particular facts and parties' submissions and was expressly not a precedent.
Note: It is a system-generated summary and is for quick reference only.