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...
The Tribunal held that the enhancement of the stamp duty valuation tolerance band from 5% to 10% was a curative, beneficial amendment applicable to A.Y. 2018-19, because it only relaxed the rigour of a deeming provision and did not create a new charge or fresh burden. It further held that the deeming fiction under section 56(2)(x)(b)(B) could not be invoked where the difference between the purchase consideration and the stamp duty value was 7.44%, being within the 10% band. The addition was deleted.
The Tribunal held that the enhancement of the stamp duty valuation tolerance band from 5% to 10% was a curative, beneficial amendment applicable to A.Y. 2018-19, because it only relaxed the rigour of a deeming provision and did not create a new charge or fresh burden. It further held that the deeming fiction under section 56(2)(x)(b)(B) could not be invoked where the difference between the purchase consideration and the stamp duty value was 7.44%, being within the 10% band. The addition was deleted.
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