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...
Penalty notices must specify whether the alleged default is concealment of income or furnishing inaccurate particulars; retaining both alternatives without identifying the charge indicates non-application of mind and may deny an adequate opportunity to respond. The notes also address penalties for delayed employees' provident fund contributions and book-profit adjustments, stating that a debatable disallowance or mere rejection of a claim does not itself establish concealment, inaccurate particulars, or wilful tax evasion. An excess weighted research deduction claimed on disclosed material before subsequent approval may be bona fide. Penalty for under-reporting also requires identification and communication of the applicable statutory circumstance, failing which proceedings breach natural justice.
Penalty notices must specify whether the alleged default is concealment of income or furnishing inaccurate particulars; retaining both alternatives without identifying the charge indicates non-application of mind and may deny an adequate opportunity to respond. The notes also address penalties for delayed employees' provident fund contributions and book-profit adjustments, stating that a debatable disallowance or mere rejection of a claim does not itself establish concealment, inaccurate particulars, or wilful tax evasion. An excess weighted research deduction claimed on disclosed material before subsequent approval may be bona fide. Penalty for under-reporting also requires identification and communication of the applicable statutory circumstance, failing which proceedings breach natural justice.
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