Reassessment under s.148A held valid; s.69 additions totaling Rs.7,00,000 deleted after acceptable contemporaneous explanations for property investmen...
Adjudication set aside; Rule 9 valuation based on internet engineer report quashed for Rule 3(4) non-compliance; Section 138B cross-examination requir...
The HC affirms that inspection and seizure disclosed largescale suppression of purchases, sales and stock; private notebooks and an admission at inspection established transactions outside books. Once suppression was established, the burden shifted to the respondent to prove the entries were mere job-work ("coolie conversion"), which was not discharged and was raised only on appeal. The Assessing Officer's determination of suppressed turnover, grounded on seized material and contemporaneous statements, was upheld as evidentiary and rational. The Appellate Assistant Commissioner's and Tribunal's deletions of assessed turnover were set aside. The Assessing Officer's order is restored, the tax revision is allowed, and the substantial questions of law are answered in favour of the Revenue.
The HC affirms that inspection and seizure disclosed largescale suppression of purchases, sales and stock; private notebooks and an admission at inspection established transactions outside books. Once suppression was established, the burden shifted to the respondent to prove the entries were mere job-work ("coolie conversion"), which was not discharged and was raised only on appeal. The Assessing Officer's determination of suppressed turnover, grounded on seized material and contemporaneous statements, was upheld as evidentiary and rational. The Appellate Assistant Commissioner's and Tribunal's deletions of assessed turnover were set aside. The Assessing Officer's order is restored, the tax revision is allowed, and the substantial questions of law are answered in favour of the Revenue.
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