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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Fair market rent for business premises cannot be enhanced merely on an Inspector's report or comparison with a different property in another city when no credible material shows that a similarly situated property in the same locality would fetch higher rent; the assessee's disclosed rent was accepted as reasonable and the addition for understated rental income was deleted. Salary paid to the assessee's son was treated as genuine business expenditure where the record showed regular engagement in the family business, work at both business locations, past payment history, growing turnover and profits, and taxability in the recipient's hands; the disallowance was set aside and deleted. The appeal was partly allowed, with remaining grounds treated as not pressed or consequential.
Fair market rent for business premises cannot be enhanced merely on an Inspector's report or comparison with a different property in another city when no credible material shows that a similarly situated property in the same locality would fetch higher rent; the assessee's disclosed rent was accepted as reasonable and the addition for understated rental income was deleted. Salary paid to the assessee's son was treated as genuine business expenditure where the record showed regular engagement in the family business, work at both business locations, past payment history, growing turnover and profits, and taxability in the recipient's hands; the disallowance was set aside and deleted. The appeal was partly allowed, with remaining grounds treated as not pressed or consequential.
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