Year-wise GST tax periods make composite show cause notices impermissible, requiring separate proceedings despite contrary non-jurisdictional preceden...
Prior APA methodology guides transfer pricing benchmarking where consistent FAR profiles support comparability and arm's length margins eliminate adju...
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Determination of sale consideration - reliance on photocopy of the alleged agreement to sell - The High Court scrutinized the circumstances surrounding the photocopy of the agreement to sell. It noted that the original document was not produced, and there was no other evidence to corroborate the details mentioned in the photocopy. Therefore, the court concluded that the photocopy alone could not serve as a valid basis for making additions to the assessee's income. - The court emphasized that the burden of proving the authenticity of the photocopy rested with the Revenue, especially since the entire case relied solely on it.
Determination of sale consideration - reliance on photocopy of the alleged agreement to sell - The High Court scrutinized the circumstances surrounding the photocopy of the agreement to sell. It noted that the original document was not produced, and there was no other evidence to corroborate the details mentioned in the photocopy. Therefore, the court concluded that the photocopy alone could not serve as a valid basis for making additions to the assessee's income. - The court emphasized that the burden of proving the authenticity of the photocopy rested with the Revenue, especially since the entire case relied solely on it.
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