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...
HC held that reassessment based on seized third-party material requires prima facie material with a live link to the assessee and the alleged escapement of income. A loose paper seized from a broker, which did not name the assessee or contain identifiable particulars, could not by itself support an on-money allegation, especially when the rate was sought to be applied years later through a sale deed record. The broker's statement also did not connect the assessee with the document. The Court said the Revenue must assess the seized material with attendant circumstances and record prima facie relevance; vague, irrelevant and non-specific material could not justify reopening. The reassessment notice was quashed.
HC held that reassessment based on seized third-party material requires prima facie material with a live link to the assessee and the alleged escapement of income. A loose paper seized from a broker, which did not name the assessee or contain identifiable particulars, could not by itself support an on-money allegation, especially when the rate was sought to be applied years later through a sale deed record. The broker's statement also did not connect the assessee with the document. The Court said the Revenue must assess the seized material with attendant circumstances and record prima facie relevance; vague, irrelevant and non-specific material could not justify reopening. The reassessment notice was quashed.
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