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...
Limitation for penalty proceedings under the second limb of the penalty-limitation provision applied where no assessment proceedings had been initiated for the relevant years. On the stated facts, the penalty notice was issued independently on the basis of a statement recorded in another person's scrutiny proceedings, so the first limb, tied to completion of proceedings in which penalty action was initiated, did not apply. The limitation therefore ran for six months from the end of the month in which penalty action was initiated. The Tribunal treated the penalty orders as time-barred and quashed them, leaving the other grounds open as academic.
Limitation for penalty proceedings under the second limb of the penalty-limitation provision applied where no assessment proceedings had been initiated for the relevant years. On the stated facts, the penalty notice was issued independently on the basis of a statement recorded in another person's scrutiny proceedings, so the first limb, tied to completion of proceedings in which penalty action was initiated, did not apply. The limitation therefore ran for six months from the end of the month in which penalty action was initiated. The Tribunal treated the penalty orders as time-barred and quashed them, leaving the other grounds open as academic.
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