Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Ad hoc gross profit estimation was held inappropriate where the Revenue sought to reject books of account after a survey and treat surrendered excess stock as a basis for additional income. The Tribunal noted that gross profit rates may vary between pre-survey and post-survey periods because market prices fluctuate, and that excess stock found in survey must be brought into the books and reflected in closing stock at the lower of cost or market price under AS-2. On that reasoning, the books could not be rejected on the stated grounds and the addition founded on ad hoc gross profit estimation was not sustainable.
Ad hoc gross profit estimation was held inappropriate where the Revenue sought to reject books of account after a survey and treat surrendered excess stock as a basis for additional income. The Tribunal noted that gross profit rates may vary between pre-survey and post-survey periods because market prices fluctuate, and that excess stock found in survey must be brought into the books and reflected in closing stock at the lower of cost or market price under AS-2. On that reasoning, the books could not be rejected on the stated grounds and the addition founded on ad hoc gross profit estimation was not sustainable.
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