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...
Properties treated as proceeds of crime remained attachable where the appellants failed to prove acquisition from independent lawful sources or payment of consideration. The Appellate Tribunal found that the respondent had established the foundational case that the assets originally stood with M/s AGFVIL and were later transferred through intermediary, namesake transactions without supporting proof of genuine purchase. For one appellant, the record showed only a shifted name without documentary evidence of consideration; for another, alleged loans, seller payment, and bank trail were not substantiated; for the third, the later explanation of source was inconsistent with her own statement and unsupported by material. The confirmation of the provisional attachment was upheld.
Properties treated as proceeds of crime remained attachable where the appellants failed to prove acquisition from independent lawful sources or payment of consideration. The Appellate Tribunal found that the respondent had established the foundational case that the assets originally stood with M/s AGFVIL and were later transferred through intermediary, namesake transactions without supporting proof of genuine purchase. For one appellant, the record showed only a shifted name without documentary evidence of consideration; for another, alleged loans, seller payment, and bank trail were not substantiated; for the third, the later explanation of source was inconsistent with her own statement and unsupported by material. The confirmation of the provisional attachment was upheld.
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