Proportionality in tax assessments preserved: additions limited to profit element where sales are accepted, not entire purchase. Alleged accommodation entries may be restricted to taxation of the profit element where sales from those purchases are accepted; the tribunal limited an ... Summary
Proportionality in tax assessments preserved: additions limited to profit element where sales are accepted, not entire purchase.
Alleged accommodation entries may be restricted to taxation of the profit element where sales from those purchases are accepted; the tribunal limited an addition accordingly and the court upheld that proportionality. Separately, an enhanced gross profit addition was deleted because there was no concrete evidence to displace the assessee's declared book results; the court agreed that revenue must meet the evidentiary burden before altering declared figures.
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