Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
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A provisional stock statement furnished to a bank for cash credit purposes could not displace audited closing stock where the Assessing Officer found no defect in the books, stock records, or valuation method and did not reject the accounts. The Tribunal accepted that the banking figures were estimated and also materially differed in sales, debtors, and creditors, showing they were not final accounts. It further held that any increase in closing stock would require a corresponding opening stock adjustment in the next year, making the proposed addition revenue-neutral where the tax rate and positive taxable income remained the same. The addition was therefore deleted.
A provisional stock statement furnished to a bank for cash credit purposes could not displace audited closing stock where the Assessing Officer found no defect in the books, stock records, or valuation method and did not reject the accounts. The Tribunal accepted that the banking figures were estimated and also materially differed in sales, debtors, and creditors, showing they were not final accounts. It further held that any increase in closing stock would require a corresponding opening stock adjustment in the next year, making the proposed addition revenue-neutral where the tax rate and positive taxable income remained the same. The addition was therefore deleted.
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