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...
Unaccounted business receipts from a garment-export business were treated as business turnover, so only the embedded gross profit, rather than the full receipts, was taxable. Based on the audited profitability trend, the reported ITAT decision restricted the gross-profit estimate to 1% of aggregated unaccounted sales, including token-note receipts. Alleged cash-salary additions were deleted because the recipient's statements were contradictory, cross-examination denied cash or cheque salary, and no independent support existed. Additions for cash, a gold coin and foreign currency were also deleted because recorded balances, the gift explanation and client confirmation of currency ownership remained unrebutted.
Unaccounted business receipts from a garment-export business were treated as business turnover, so only the embedded gross profit, rather than the full receipts, was taxable. Based on the audited profitability trend, the reported ITAT decision restricted the gross-profit estimate to 1% of aggregated unaccounted sales, including token-note receipts. Alleged cash-salary additions were deleted because the recipient's statements were contradictory, cross-examination denied cash or cheque salary, and no independent support existed. Additions for cash, a gold coin and foreign currency were also deleted because recorded balances, the gift explanation and client confirmation of currency ownership remained unrebutted.
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