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...
Unexplained investment in immovable property under section 69 was held explained where the assessee produced the sale deed, the father's bank statement, and proof of direct payment to the seller through banking channels. The Tribunal held that this discharged the primary onus; the burden then shifted to the Revenue to bring adverse material, which it did not. Mere suspicion about antecedent credits in the father's account was insufficient, and the absence of a formal gift deed did not by itself make the investment unexplained in a family transaction. The addition was deleted in full.
Unexplained investment in immovable property under section 69 was held explained where the assessee produced the sale deed, the father's bank statement, and proof of direct payment to the seller through banking channels. The Tribunal held that this discharged the primary onus; the burden then shifted to the Revenue to bring adverse material, which it did not. Mere suspicion about antecedent credits in the father's account was insufficient, and the absence of a formal gift deed did not by itself make the investment unexplained in a family transaction. The addition was deleted in full.
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