Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
Unaccounted quarry sales establish suppressed business transactions, but only the profit reasonably embedded in those sales is taxable; extraction, production and operating costs cannot be treated as income absent evidence of unexplained funding. Profit estimation must have a rational link to the taxpayer's own historical results and accounted-business profitability; an unverified external gross-profit margin cannot be substituted for net profit. The voluntarily offered profit rates were accepted, displacing the higher rate. Cash sales captured in seized data cannot be added separately where aggregate records, annual accounts and GST disclosures show they were already included in disclosed turnover; a further profit addition would duplicate the same sales.
Unaccounted quarry sales establish suppressed business transactions, but only the profit reasonably embedded in those sales is taxable; extraction, production and operating costs cannot be treated as income absent evidence of unexplained funding. Profit estimation must have a rational link to the taxpayer's own historical results and accounted-business profitability; an unverified external gross-profit margin cannot be substituted for net profit. The voluntarily offered profit rates were accepted, displacing the higher rate. Cash sales captured in seized data cannot be added separately where aggregate records, annual accounts and GST disclosures show they were already included in disclosed turnover; a further profit addition would duplicate the same sales.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4908 
