Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Credit-note turnover adjustments preserve inverted-duty refunds, while ministerial re-computation does not constitute an impermissible appellate reman...
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Rejection of books of account may be sustained where primary books, bills and vouchers are repeatedly not produced; an audit report does not replace records required for verification. Best-judgment disallowance of unverifiable expenditure must nevertheless rest on relevant material and bear a reasonable nexus to it, rather than amounting to a pure guess. Rejection of accounts alone does not justify an addition, and acceptance of recorded receipts or absence of objection to a proposed rate cannot supply evidentiary reasons. Adjacent-year audited financial statements, books and vouchers may be verified for fresh quantification after hearing.
Rejection of books of account may be sustained where primary books, bills and vouchers are repeatedly not produced; an audit report does not replace records required for verification. Best-judgment disallowance of unverifiable expenditure must nevertheless rest on relevant material and bear a reasonable nexus to it, rather than amounting to a pure guess. Rejection of accounts alone does not justify an addition, and acceptance of recorded receipts or absence of objection to a proposed rate cannot supply evidentiary reasons. Adjacent-year audited financial statements, books and vouchers may be verified for fresh quantification after hearing.
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