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...
Selective revaluation noted by the auditor did not by itself disqualify certified accounts for MAT purposes or justify excluding depreciation on the revaluation component from book profit. The High Court held that once the accounts complied with the Companies Act and were certified under the statutory audit framework, the Assessing Officer could not go behind the book profit except to the limited extent permitted under the MAT provisions. The Tribunal erred in treating the auditor's qualification note as undermining the true and fair view of the accounts; the assessee succeeded and the CIT(A)'s order was restored.
Selective revaluation noted by the auditor did not by itself disqualify certified accounts for MAT purposes or justify excluding depreciation on the revaluation component from book profit. The High Court held that once the accounts complied with the Companies Act and were certified under the statutory audit framework, the Assessing Officer could not go behind the book profit except to the limited extent permitted under the MAT provisions. The Tribunal erred in treating the auditor's qualification note as undermining the true and fair view of the accounts; the assessee succeeded and the CIT(A)'s order was restored.
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