Evidentiary substantiation in assessments: unsupported cash deposits, land-facilitation receipts, and GST sales supported additions and business-income treatment.
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....Natural justice is not breached where the taxpayer receives repeated opportunities, issue-specific show-cause notices, and consideration of replies and evidence; the challenge to assessment validity therefore failed. Cash deposits require credible proof of source and a transaction-specific cash trail; unsupported deposits were treated as unexplained money. Consideration for land-facilitation work was characterised as business income because the land was not established as a capital asset and no refundable obligation was proved. GST-reported sales omitted from the revised income-tax return were treated as undisclosed business receipts absent cogent rebuttal. The contested additions and assessment were sustained.....
TaxTMI