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...
Jurisdiction under section 124 was rejected because the assessment had been authorised under section 120(4)(b), notices were issued by the Additional Commissioner, and no timely objection was raised; the jurisdictional ground was admitted but dismissed on merits. The India-Germany DDT treaty claim was remitted for limited verification of treaty documents and eligibility under the binding High Court ruling. Provisions for liquidated damages and warranty were treated as allowable in principle but 50% disallowed for excess quantification, with directions to prevent double taxation on later reversal or utilisation. The section 145A adjustment and commission disallowance were deleted, while actuarially valued employee benefit provisions were upheld.
Jurisdiction under section 124 was rejected because the assessment had been authorised under section 120(4)(b), notices were issued by the Additional Commissioner, and no timely objection was raised; the jurisdictional ground was admitted but dismissed on merits. The India-Germany DDT treaty claim was remitted for limited verification of treaty documents and eligibility under the binding High Court ruling. Provisions for liquidated damages and warranty were treated as allowable in principle but 50% disallowed for excess quantification, with directions to prevent double taxation on later reversal or utilisation. The section 145A adjustment and commission disallowance were deleted, while actuarially valued employee benefit provisions were upheld.
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