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...
Penalty under section 271(1)(c) was held unsustainable where the disallowance arose from a deduction claim under section 80IB(10) on which courts had taken divergent views. The Tribunal treated the issue as debatable, noted that the controversy was pending before the Supreme Court, and applied Reliance Petroproducts to hold that a merely unsustainable claim does not amount to concealment or furnishing inaccurate particulars. On that basis, the statutory conditions for penalty were not met and the penalty was deleted.
Penalty under section 271(1)(c) was held unsustainable where the disallowance arose from a deduction claim under section 80IB(10) on which courts had taken divergent views. The Tribunal treated the issue as debatable, noted that the controversy was pending before the Supreme Court, and applied Reliance Petroproducts to hold that a merely unsustainable claim does not amount to concealment or furnishing inaccurate particulars. On that basis, the statutory conditions for penalty were not met and the penalty was deleted.
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