Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Admissibility of seized diaries showing unaccounted sales under code "802" was accepted as business records and the Tribunal estimated unaccounted business income by applying a 2.5% net profit margin on gross receipts, the addition to be over and above returned income. Once profit on those receipts is taxed, subsequent additions for payments or investments funded from the same receipts (including payment to a jewellery supplier and acquisition of jewellery and bars) were deleted. Separate additions for an alleged cash payment, payments to an identified individual, land deal cash, and a vehicle payment were set aside for lack of corroborative evidence or because they were subsumed by the profit estimation; telescoping benefit was allowed.
Admissibility of seized diaries showing unaccounted sales under code "802" was accepted as business records and the Tribunal estimated unaccounted business income by applying a 2.5% net profit margin on gross receipts, the addition to be over and above returned income. Once profit on those receipts is taxed, subsequent additions for payments or investments funded from the same receipts (including payment to a jewellery supplier and acquisition of jewellery and bars) were deleted. Separate additions for an alleged cash payment, payments to an identified individual, land deal cash, and a vehicle payment were set aside for lack of corroborative evidence or because they were subsumed by the profit estimation; telescoping benefit was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
