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...
For unexplained investment in property purchases, an addition under section 69 cannot rest solely on an unauthenticated loose sheet seized from a third party. The notes state that the sheet was unsigned, not part of regular accounts, inconsistent with registered conveyance and banking records, and unconnected to the assessee or sellers. Without proof of the document's author, independent seller enquiries, evidence of on-money receipt, a cash trail, or other corroboration, the Revenue does not discharge its burden to prove understated consideration. Loose sheets or dumb documents are not substantive evidence by themselves, and suspicion cannot replace proof. The addition was deleted; issues concerning section 153C validity, the satisfaction note, and cross-examination remained open.
For unexplained investment in property purchases, an addition under section 69 cannot rest solely on an unauthenticated loose sheet seized from a third party. The notes state that the sheet was unsigned, not part of regular accounts, inconsistent with registered conveyance and banking records, and unconnected to the assessee or sellers. Without proof of the document's author, independent seller enquiries, evidence of on-money receipt, a cash trail, or other corroboration, the Revenue does not discharge its burden to prove understated consideration. Loose sheets or dumb documents are not substantive evidence by themselves, and suspicion cannot replace proof. The addition was deleted; issues concerning section 153C validity, the satisfaction note, and cross-examination remained open.
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