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...
The Appellate Tribunal addressed several issues. Regarding quantification of profit element on unsubstantiated purchases, the matter was sent back to the Assessing Officer (\u/s) for limited addition based on profit rate variance. Disallowance of interest on loan was allowed for further evidence consideration. Addition \u/s 68 for unsecured loans was revisited due to new documents submitted, leading to a direction for reassessment by the AO. The assessee's appeals were allowed for statistical purposes. The AO was instructed to provide a fair opportunity for the assessee in each case.
The Appellate Tribunal addressed several issues. Regarding quantification of profit element on unsubstantiated purchases, the matter was sent back to the Assessing Officer (\u/s) for limited addition based on profit rate variance. Disallowance of interest on loan was allowed for further evidence consideration. Addition \u/s 68 for unsecured loans was revisited due to new documents submitted, leading to a direction for reassessment by the AO. The assessee's appeals were allowed for statistical purposes. The AO was instructed to provide a fair opportunity for the assessee in each case.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
