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...
Revised post-survey construction cost estimates, TDR and development rights allocation, and GST impact on project cost under the Percentage of Completion Method depended on detailed factual verification. The text notes that the revised projections were linked to changes in floor plans, phase-wise utilisation of development rights, denial of input tax credit under the revised GST scheme, and consistency of revenue recognition with registered agreements. It records that broad explanations and estimated workings were insufficient, so the revised computation could not be finally accepted without examining the factual foundation. The disputed additions were therefore set aside and the matter was remanded for de novo verification and fresh decision for both assessment years.
Revised post-survey construction cost estimates, TDR and development rights allocation, and GST impact on project cost under the Percentage of Completion Method depended on detailed factual verification. The text notes that the revised projections were linked to changes in floor plans, phase-wise utilisation of development rights, denial of input tax credit under the revised GST scheme, and consistency of revenue recognition with registered agreements. It records that broad explanations and estimated workings were insufficient, so the revised computation could not be finally accepted without examining the factual foundation. The disputed additions were therefore set aside and the matter was remanded for de novo verification and fresh decision for both assessment years.
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