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 for misreporting under section 270A requires the assessing authority to identify the precise limb in section 270A(9) and explain how the additions satisfy that clause. A mere ad hoc disallowance of labour or loading and unloading charges, or a disallowance based on alleged non-deduction of tax at source, does not by itself establish misreporting of income. The text also notes that email-only appellate notices, when the assessee had opted for another mode, do not justify an adverse inference from non-appearance. On that reasoning, the penalty was deleted.
Penalty for misreporting under section 270A requires the assessing authority to identify the precise limb in section 270A(9) and explain how the additions satisfy that clause. A mere ad hoc disallowance of labour or loading and unloading charges, or a disallowance based on alleged non-deduction of tax at source, does not by itself establish misreporting of income. The text also notes that email-only appellate notices, when the assessee had opted for another mode, do not justify an adverse inference from non-appearance. On that reasoning, the penalty was deleted.
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