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...
Audited financial statements separately disclosed agricultural income and non-agricultural income, with the non-agricultural component offered to tax and the agricultural income claimed exempt. The Tribunal held that the first appellate authority proceeded on an incorrect factual premise in stating that no bifurcation existed. Because the audited statements were before the assessing and appellate authorities and the income and expenditure figures were not disputed, the claim of exempt agricultural income was accepted. The addition made by treating the agricultural income as business income was deleted.
Audited financial statements separately disclosed agricultural income and non-agricultural income, with the non-agricultural component offered to tax and the agricultural income claimed exempt. The Tribunal held that the first appellate authority proceeded on an incorrect factual premise in stating that no bifurcation existed. Because the audited statements were before the assessing and appellate authorities and the income and expenditure figures were not disputed, the claim of exempt agricultural income was accepted. The addition made by treating the agricultural income as business income was deleted.
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