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...
Section 53A of the Transfer of Property Act did not confer ownership for depreciation where there was no written and registered transfer instrument, so the assessee could not treat the properties as firm assets or claim depreciation on that basis. The assessment was also not vitiated by natural justice grounds because the show-cause process and repeated notices already covered the relevant factual basis, and the shift from unexplained investment to unexplained credit was treated as a consequence of the same inquiry. Having rejected the jurisdictional and procedural objections, the Court declined to examine the merits of the unexplained credit dispute in writ jurisdiction and relegated the assessee to the statutory appellate remedy.
Section 53A of the Transfer of Property Act did not confer ownership for depreciation where there was no written and registered transfer instrument, so the assessee could not treat the properties as firm assets or claim depreciation on that basis. The assessment was also not vitiated by natural justice grounds because the show-cause process and repeated notices already covered the relevant factual basis, and the shift from unexplained investment to unexplained credit was treated as a consequence of the same inquiry. Having rejected the jurisdictional and procedural objections, the Court declined to examine the merits of the unexplained credit dispute in writ jurisdiction and relegated the assessee to the statutory appellate remedy.
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