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...
The pre-2001 Karnataka sales tax exemption for sugar covered imported sugar because the reference to the Additional Duties of Excise Act identified the commodity without imposing an origin-based limitation. The 2001 amendment restricting the exemption to sugar produced or manufactured in India was substantive and retrospective, but remained within legislative competence and was constitutionally valid. Retrospective taxation could determine the principal tax liability, while penalty was unavailable for transactions previously treated as exempt and interest could apply only from the lawful reassessment demand. Inter-State sales remained governed by the Central Sales Tax Act, including its applicable rate and conditions, requiring recomputation for the relevant period.
The pre-2001 Karnataka sales tax exemption for sugar covered imported sugar because the reference to the Additional Duties of Excise Act identified the commodity without imposing an origin-based limitation. The 2001 amendment restricting the exemption to sugar produced or manufactured in India was substantive and retrospective, but remained within legislative competence and was constitutionally valid. Retrospective taxation could determine the principal tax liability, while penalty was unavailable for transactions previously treated as exempt and interest could apply only from the lawful reassessment demand. Inter-State sales remained governed by the Central Sales Tax Act, including its applicable rate and conditions, requiring recomputation for the relevant period.
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