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...
Where sales were fully recorded in the assessee's books and there was no evidence of suppressed sales, a separate 6% profit addition on those sales was impermissible even though the counterparties were alleged bogus entities. The Tribunal had sustained addition only on the bogus purchases, and no material displaced that factual basis. The Assessing Officer had not recorded any finding that the sales themselves were bogus or that a further sales addition was warranted. The HC therefore dismissed the revenue's appeals and upheld rejection of the further profit addition.
Where sales were fully recorded in the assessee's books and there was no evidence of suppressed sales, a separate 6% profit addition on those sales was impermissible even though the counterparties were alleged bogus entities. The Tribunal had sustained addition only on the bogus purchases, and no material displaced that factual basis. The Assessing Officer had not recorded any finding that the sales themselves were bogus or that a further sales addition was warranted. The HC therefore dismissed the revenue's appeals and upheld rejection of the further profit addition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
