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...
Expenditure is disallowable under Explanation 1 to section 37(1) only where it is shown to relate to an offence or an act prohibited by law; because no punitive action had been taken by the competent insurance regulator, the disallowance was deleted. For insurance business income, section 44 with the First Schedule provides a special computation regime that overrides the general computation rules, so section 14A read with Rule 8D does not apply to an insurer. The prior co-ordinate bench view in the assessee's own case was followed.
Expenditure is disallowable under Explanation 1 to section 37(1) only where it is shown to relate to an offence or an act prohibited by law; because no punitive action had been taken by the competent insurance regulator, the disallowance was deleted. For insurance business income, section 44 with the First Schedule provides a special computation regime that overrides the general computation rules, so section 14A read with Rule 8D does not apply to an insurer. The prior co-ordinate bench view in the assessee's own case was followed.
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