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...
Reassessment initiated after four years from the end of the assessment year was held invalid where the original assessment had been completed under scrutiny and the recorded reasons showed that the information on alleged accommodation entries was already available during that assessment. In the absence of any allegation in the reasons that the assessee had failed to disclose fully and truly all material facts, the jurisdictional requirement for reopening beyond four years was not met. The notice under section 148 and the consequential reassessment order were quashed, and the merits of the additions were left unexamined.
Reassessment initiated after four years from the end of the assessment year was held invalid where the original assessment had been completed under scrutiny and the recorded reasons showed that the information on alleged accommodation entries was already available during that assessment. In the absence of any allegation in the reasons that the assessee had failed to disclose fully and truly all material facts, the jurisdictional requirement for reopening beyond four years was not met. The notice under section 148 and the consequential reassessment order were quashed, and the merits of the additions were left unexamined.
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