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...
Mechanical approval for search assessments under section 153D was held invalid where the sanction was consolidated, year-neutral and showed no application of mind, so the assessments were quashed as void ab initio. Completed years could not be reopened under section 153A in the absence of incriminating material. Where the Revenue relied on documents from a third party's search, the mandatory section 153C route had to be followed, and assessments framed without it were without jurisdiction. The Tribunal also deleted additions based on estimated project income, loose sheets without corroboration, assumed project receipts, and cash deposits supported by agricultural records and sale documents.
Mechanical approval for search assessments under section 153D was held invalid where the sanction was consolidated, year-neutral and showed no application of mind, so the assessments were quashed as void ab initio. Completed years could not be reopened under section 153A in the absence of incriminating material. Where the Revenue relied on documents from a third party's search, the mandatory section 153C route had to be followed, and assessments framed without it were without jurisdiction. The Tribunal also deleted additions based on estimated project income, loose sheets without corroboration, assumed project receipts, and cash deposits supported by agricultural records and sale documents.
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