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...
With effect from conversion, the LLP was a separate legal entity, so municipal and property taxes attributable to the pre-conversion period belonged to the erstwhile private limited company and could not be claimed by the LLP as its own expenditure or loss. The Tribunal therefore sustained the disallowance of the pre-conversion taxes, noting that the assessee's relied-upon provisions did not apply on the facts found and that the earlier company had not filed a return. However, it accepted the alternative claim that income assessed under the head house property must carry the statutory standard deduction and directed the Assessing Officer to allow it.
With effect from conversion, the LLP was a separate legal entity, so municipal and property taxes attributable to the pre-conversion period belonged to the erstwhile private limited company and could not be claimed by the LLP as its own expenditure or loss. The Tribunal therefore sustained the disallowance of the pre-conversion taxes, noting that the assessee's relied-upon provisions did not apply on the facts found and that the earlier company had not filed a return. However, it accepted the alternative claim that income assessed under the head house property must carry the statutory standard deduction and directed the Assessing Officer to allow it.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
