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...
Protective addition failed where the cash allegedly routed for gold purchase was owned up by other persons and the assessee was shown only as a facilitator, so the cash could not be taxed in his hands. Commission income was also deleted in the Prateek Bansal gold transaction because Bansal admitted the transaction and its profit, and there was no material for a separate commission to the assessee. For the seized 2 kg gold, ownership remained unclear; verification from the Enforcement Directorate was directed before deciding whether it was assessable as commission in the assessee's hands or in the company's hands.
Protective addition failed where the cash allegedly routed for gold purchase was owned up by other persons and the assessee was shown only as a facilitator, so the cash could not be taxed in his hands. Commission income was also deleted in the Prateek Bansal gold transaction because Bansal admitted the transaction and its profit, and there was no material for a separate commission to the assessee. For the seized 2 kg gold, ownership remained unclear; verification from the Enforcement Directorate was directed before deciding whether it was assessable as commission in the assessee's hands or in the company's hands.
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