Unverifiable Purchases: accepted sales support profit-element addition, while transaction-specific intelligence sustains reassessment jurisdiction and limits remand.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Transaction-specific investigation information identifying the taxpayer, supplier and disputed transaction can support reassessment under the substituted regime after pre-notice procedure; its Investigation Wing origin alone does not make it vague. A retrospective clarification permits a Jurisdictional Assessing Officer to issue the reassessment notice. Where corresponding sales, purchase records and banking evidence exist but the named supplier is untraceable and does not comply, purchases cannot be wholly disallowed; absent evidence that payments returned in cash, addition is limited to the embedded profit. The disputed-purchase addition was restricted to 6%. A monetary-limit exception for departmental appeals affects maintainability but does not itself require vacating the appellate order or remanding assessment.....