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...
Clause 10(e) of the CBDT circular on low-tax-effect appeals was construed as an exception covering enforcement agencies akin to CBI, ED, DRI, SFIO and DGGI, rather than those names alone. On that interpretation, the VAT department was treated as falling within the exception because it functioned as an enforcement agency. The Tribunal therefore misread the circular by excluding VAT merely because it was not expressly named. The order rejecting the Revenue's rectification application was set aside, and the matter was restored to the Tribunal for decision on merits after hearing both sides.
Clause 10(e) of the CBDT circular on low-tax-effect appeals was construed as an exception covering enforcement agencies akin to CBI, ED, DRI, SFIO and DGGI, rather than those names alone. On that interpretation, the VAT department was treated as falling within the exception because it functioned as an enforcement agency. The Tribunal therefore misread the circular by excluding VAT merely because it was not expressly named. The order rejecting the Revenue's rectification application was set aside, and the matter was restored to the Tribunal for decision on merits after hearing both sides.
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