Suppressed sales records can establish tax liability, while taxpayer-initiated remands cannot worsen an appellant's position.
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....Rule 56(10) creates a rebuttable presumption of maintenance for a registered person's records, even when found away from registered premises. Records linked to a trader by their contents, custody and an admission can establish suppressed sales on a balance of probabilities. Section 74 applies to deliberate suppression with intent to evade tax, attracting a penalty equal to tax; a shortfall or bona fide mistake alone is insufficient. Enhancement-notice requirements do not apply where the fresh determination reduces the original demand covered by the notice. An appellant-initiated remand cannot worsen the appellant's position: the earlier appellate determination caps tax, penalty and interest accrued up to that determination, while statutory .........
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