Proceeds of crime: provisional attachment confirmed; equivalent value attachment and acquisition date fair market value upheld, Covid exclusion preser...
Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
Dominant issue: whether the assessing officer's estimate of gross agricultural receipts should be sustained. Reasoning: AO conceded the taxpayer carried on agricultural activity but disputed the correctness of reported gross agricultural receipts; taxpayer produced invoices and buyer confirmations but also some self-serving documents of limited evidentiary value; taxpayer's historical consistency in reporting agricultural income was considered. Outcome: directed AO to make an ad-hoc addition equal to 10% of agricultural receipts, taxed at normal rates; appeal partly allowed. - ITAT
Dominant issue: whether the assessing officer's estimate of gross agricultural receipts should be sustained. Reasoning: AO conceded the taxpayer carried on agricultural activity but disputed the correctness of reported gross agricultural receipts; taxpayer produced invoices and buyer confirmations but also some self-serving documents of limited evidentiary value; taxpayer's historical consistency in reporting agricultural income was considered. Outcome: directed AO to make an ad-hoc addition equal to 10% of agricultural receipts, taxed at normal rates; appeal partly allowed. - ITAT
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