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Presumptive taxation limits profit enhancement where past margins lack adverse material contradicting the taxpayer's declared income.

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Full Text of the Document

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....Presumptive taxation does not permit enhancement of declared business profit merely by applying average profit margins from preceding years. Although the Assessing Officer may examine a claim under the presumptive taxation regime, any challenge must rest on adverse material. A taxpayer declaring income under that regime is not required to maintain books of account solely for that reason, and a stated decline in profit margin cannot be rejected without material disproving the explanation. The Tribunal's majority view found the adopted net-profit rate unjustified and allowed the taxpayer's appeal.....