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...
Section 74 does not permit a single show-cause notice to club multiple financial years, because limitation is linked to each relevant financial year and a consolidated notice would unlawfully extend the five-year period for earlier years. The impugned notice and consequential order were therefore treated as de hors the statute and without jurisdiction. The alternative-remedy rule was also held to be only a self-imposed restraint: where the defect is ex facie jurisdictional and apparent on the record, writ relief remains maintainable despite an available statutory appeal.
Section 74 does not permit a single show-cause notice to club multiple financial years, because limitation is linked to each relevant financial year and a consolidated notice would unlawfully extend the five-year period for earlier years. The impugned notice and consequential order were therefore treated as de hors the statute and without jurisdiction. The alternative-remedy rule was also held to be only a self-imposed restraint: where the defect is ex facie jurisdictional and apparent on the record, writ relief remains maintainable despite an available statutory appeal.
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