Beneficial owner held liable for differential customs duty; royalties added under Rule 10(1)(c); confiscation, penalties under s.111(m), s.114A, s.112...
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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