Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
Assessment of income on account of unsubstantiated purchases was affirmed where the assessee failed to produce parties, documents or reconcile sundry balances; the tribunal upheld CIT(A)/NFAC direction to adopt a reasonable profit rate (informed by but not applying section 44AD) instead of disallowing all purchases. Separately, disallowance under the TDS provision was sustained because audited accounts and auditor silence did not excuse the assessee's statutory failure to deduct tax at source.
Assessment of income on account of unsubstantiated purchases was affirmed where the assessee failed to produce parties, documents or reconcile sundry balances; the tribunal upheld CIT(A)/NFAC direction to adopt a reasonable profit rate (informed by but not applying section 44AD) instead of disallowing all purchases. Separately, disallowance under the TDS provision was sustained because audited accounts and auditor silence did not excuse the assessee's statutory failure to deduct tax at source.
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