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...
SEZ refund entitlement was held to depend on actual use of services for authorised operations and undisputed service tax payment, not on technical invoice defects. The Tribunal treated invoice mismatches, rubber-stamp corrections and missing originals as procedural irregularities that could not defeat substantive eligibility where receipt of services, tax payment and nexus with the SEZ unit were established. It also held that works contract services for piling and infrastructure of the approved manufacturing block fell within authorised operations on a liberal, purposive reading of the SEZ scheme, whose beneficial provisions override inconsistent documentation requirements. The refund rejection was therefore set aside and the refund held admissible.
SEZ refund entitlement was held to depend on actual use of services for authorised operations and undisputed service tax payment, not on technical invoice defects. The Tribunal treated invoice mismatches, rubber-stamp corrections and missing originals as procedural irregularities that could not defeat substantive eligibility where receipt of services, tax payment and nexus with the SEZ unit were established. It also held that works contract services for piling and infrastructure of the approved manufacturing block fell within authorised operations on a liberal, purposive reading of the SEZ scheme, whose beneficial provisions override inconsistent documentation requirements. The refund rejection was therefore set aside and the refund held admissible.
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