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...
Absence of recorded satisfaction in the assessment order for initiating penalty proceedings rendered penalty under section 271E unsustainable, where the assessment under section 143(3) accepted the returned income and contained no finding of violation of section 269T. Applying CIT v. Jai Laxmi Rice Mills, the Tribunal held that penalty proceedings cannot survive without such satisfaction in the assessment order and directed deletion of the penalty.
Absence of recorded satisfaction in the assessment order for initiating penalty proceedings rendered penalty under section 271E unsustainable, where the assessment under section 143(3) accepted the returned income and contained no finding of violation of section 269T. Applying CIT v. Jai Laxmi Rice Mills, the Tribunal held that penalty proceedings cannot survive without such satisfaction in the assessment order and directed deletion of the penalty.
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