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...
Notional partners' capital entries credited as receivable under an LLP agreement were held outside section 68 because there was no actual inflow of funds during the year, the entries were only book adjustments, and the partners' identities and creditworthiness were not materially disputed; the addition was deleted. Administrative expenditure was also allowed because the LLP had already been set up through execution of the agreement, bank account opening, professional engagement, and regulatory steps, so business expenses remained deductible even without revenue. The Tribunal therefore upheld deletion of both the section 68 addition and the disallowance of administrative expenditure and dismissed the Revenue's appeal.
Notional partners' capital entries credited as receivable under an LLP agreement were held outside section 68 because there was no actual inflow of funds during the year, the entries were only book adjustments, and the partners' identities and creditworthiness were not materially disputed; the addition was deleted. Administrative expenditure was also allowed because the LLP had already been set up through execution of the agreement, bank account opening, professional engagement, and regulatory steps, so business expenses remained deductible even without revenue. The Tribunal therefore upheld deletion of both the section 68 addition and the disallowance of administrative expenditure and dismissed the Revenue's appeal.
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