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...
Penalty under section 271DA required a clear jurisdictional foundation in the assessment order itself, including recorded satisfaction identifying the alleged cash receipt and the ingredients of section 269ST; a bare reference to penalty proceedings was insufficient, so jurisdiction failed and the penalty order was quashed. On merits, contravention had to be proved by cogent corroborative material showing person-wise, transaction-wise or event-wise receipt beyond the statutory threshold; uncorroborated tally data, statements and estimated income from rejected books did not discharge the Revenue's burden, so the penalty was deleted.
Penalty under section 271DA required a clear jurisdictional foundation in the assessment order itself, including recorded satisfaction identifying the alleged cash receipt and the ingredients of section 269ST; a bare reference to penalty proceedings was insufficient, so jurisdiction failed and the penalty order was quashed. On merits, contravention had to be proved by cogent corroborative material showing person-wise, transaction-wise or event-wise receipt beyond the statutory threshold; uncorroborated tally data, statements and estimated income from rejected books did not discharge the Revenue's burden, so the penalty was deleted.
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