Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
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Unreliable salary records justified rejection of the books of account where discrepancies in wage and salary registers remained unexplained, including mismatches with profit and loss account entries, inconsistent signatures, missing names and addresses, and unsupported cash payments. Once the books were rejected, profit had to be estimated on a rational basis; an 8 per cent net profit rate was held arbitrary because no justification was shown. The assessee's past net profit history of about 1 to 2 per cent was treated as the proper guide, and net profit was directed to be computed at 3 per cent of turnover.
Unreliable salary records justified rejection of the books of account where discrepancies in wage and salary registers remained unexplained, including mismatches with profit and loss account entries, inconsistent signatures, missing names and addresses, and unsupported cash payments. Once the books were rejected, profit had to be estimated on a rational basis; an 8 per cent net profit rate was held arbitrary because no justification was shown. The assessee's past net profit history of about 1 to 2 per cent was treated as the proper guide, and net profit was directed to be computed at 3 per cent of turnover.
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