Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
Because the assessee's returned income was below the metro-city monetary threshold in CBDT Instruction No. 1/2011, the reassessment notice under section 148 had to be issued by the ITO and not the ACIT. The Tribunal held that the ACIT lacked jurisdiction under the applicable administrative instruction, so the notice was void ab initio. As the defect went to the authority issuing the notice, the consequential reassessment proceedings were also vitiated and quashed.
Because the assessee's returned income was below the metro-city monetary threshold in CBDT Instruction No. 1/2011, the reassessment notice under section 148 had to be issued by the ITO and not the ACIT. The Tribunal held that the ACIT lacked jurisdiction under the applicable administrative instruction, so the notice was void ab initio. As the defect went to the authority issuing the notice, the consequential reassessment proceedings were also vitiated and quashed.
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