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...
Rectification of a return could not be used to enhance business income where amounts such as rent, dividend and bank interest had already been disclosed under their proper heads, because the same sums were again added to business income due to a return-filing error. On examining the return, profit and loss account and computation, the Tribunal accepted that income taxable under other heads had to be reduced from business income when computing net profit. The rectification order was based on an incorrect appreciation of the computation, and the impugned addition was deleted.
Rectification of a return could not be used to enhance business income where amounts such as rent, dividend and bank interest had already been disclosed under their proper heads, because the same sums were again added to business income due to a return-filing error. On examining the return, profit and loss account and computation, the Tribunal accepted that income taxable under other heads had to be reduced from business income when computing net profit. The rectification order was based on an incorrect appreciation of the computation, and the impugned addition was deleted.
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