Delayed judgment pronouncement alone does not invalidate Tribunal orders, while rectification cannot reopen evidence or negate confiscation-related pe...
Agricultural-land reinvestment qualifies when transfer consideration precedes replacement purchase, while unexamined claims may be reassessed on escap...
Bona fide public fixed-deposit explanations prevent concealment penalties where unexplained-credit additions lack independent evidence of undisclosed ...
Factory-consumption condition restricts solar module parts exemption and excludes imported aluminium profiles fabricated outside the production factor...
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Best-judgment assessment may be used where books of account are not maintained and required information is not furnished, but business-profit estimation must remain fair, unbiased and rational. Profit rates cannot be adopted capriciously or without supporting facts; they should be based on the taxpayer's past history or comparable businesses in the same line of trade. Where the adopted rates lack such a disclosed basis, the profit estimation requires reconsideration. Net profit must be freshly determined with reference to relevant comparables or past results after affording the taxpayer an opportunity of hearing.
Best-judgment assessment may be used where books of account are not maintained and required information is not furnished, but business-profit estimation must remain fair, unbiased and rational. Profit rates cannot be adopted capriciously or without supporting facts; they should be based on the taxpayer's past history or comparable businesses in the same line of trade. Where the adopted rates lack such a disclosed basis, the profit estimation requires reconsideration. Net profit must be freshly determined with reference to relevant comparables or past results after affording the taxpayer an opportunity of hearing.
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