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...
HC held that consistency in tax treatment required deletion of the ad hoc disallowance of telephone and car expenses where similar disallowances for earlier years had already been deleted and no material change in facts was shown. It further held that a company's expenditure cannot be treated as personal expenditure merely because employees or directors may use cars or telephones authorised by the company; disallowance is justified only on a finding that the has no nexus with business. The Court found the AO's reasoning cursory and ruled that the company was not required to maintain a log book or split journeys into personal and official use. The disallowance was set aside.
HC held that consistency in tax treatment required deletion of the ad hoc disallowance of telephone and car expenses where similar disallowances for earlier years had already been deleted and no material change in facts was shown. It further held that a company's expenditure cannot be treated as personal expenditure merely because employees or directors may use cars or telephones authorised by the company; disallowance is justified only on a finding that the has no nexus with business. The Court found the AO's reasoning cursory and ruled that the company was not required to maintain a log book or split journeys into personal and official use. The disallowance was set aside.
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