Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Whether unexplained cash deposits could be bifurcated and subjected to best judgment addition under section 144: Tribunal found bifurcation unjustified because the assessee's sole source of deposits was business receipts from trading in cement and iron-highly competitive commodities-so there was no rational basis for segregating half the deposits as unexplained; consequence: separate addition of unexplained cash deposits set aside. Appropriate profit rate to estimate business income: applying commercial realities and comparable profit standards, Tribunal directed AO to adopt a 6% profit rate on entire receipts and recompute income; appeal partly allowed. - ITAT
Whether unexplained cash deposits could be bifurcated and subjected to best judgment addition under section 144: Tribunal found bifurcation unjustified because the assessee's sole source of deposits was business receipts from trading in cement and iron-highly competitive commodities-so there was no rational basis for segregating half the deposits as unexplained; consequence: separate addition of unexplained cash deposits set aside. Appropriate profit rate to estimate business income: applying commercial realities and comparable profit standards, Tribunal directed AO to adopt a 6% profit rate on entire receipts and recompute income; appeal partly allowed. - ITAT
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