Person chargeable with duty must be the importer at importation; subsequent purchasers cannot be held liable where beneficial owner rules did not appl...
Bogus purchase additions based on estimated profit were deleted where the assessee produced GST-linked purchase records, quantitative stock statements, movement details and payment evidence, and none of those books or results were found defective. In the absence of rejection of books or any finding that the disclosed gross profit was unreasonable, an 8% profit estimate on alleged bogus purchases was impermissible. The addition for alleged cessation of liability was also deleted because the ledger balance was supported by invoices and bank payments, and no adverse factual finding displaced that documentary evidence.
Bogus purchase additions based on estimated profit were deleted where the assessee produced GST-linked purchase records, quantitative stock statements, movement details and payment evidence, and none of those books or results were found defective. In the absence of rejection of books or any finding that the disclosed gross profit was unreasonable, an 8% profit estimate on alleged bogus purchases was impermissible. The addition for alleged cessation of liability was also deleted because the ledger balance was supported by invoices and bank payments, and no adverse factual finding displaced that documentary evidence.
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