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...
Validity of assessment u/s 153C - Period of limitation - Assessment of income of any other person in search proceedings - The proviso in Section 153C(1) includes not only the question of abatement but also determines the date from which the six-year limitation period should be calculated. - The High court analyzed the relevant legal provisions and case law, emphasizing the need to prevent prejudice to affected parties due to delayed proceedings. It concluded that the assessment orders were indeed barred by limitation, highlighting the unjustified delay in recording satisfaction. Considering the statutory limitation period and lapse of time for completing the assessment, the court quashed the assessment orders.
Validity of assessment u/s 153C - Period of limitation - Assessment of income of any other person in search proceedings - The proviso in Section 153C(1) includes not only the question of abatement but also determines the date from which the six-year limitation period should be calculated. - The High court analyzed the relevant legal provisions and case law, emphasizing the need to prevent prejudice to affected parties due to delayed proceedings. It concluded that the assessment orders were indeed barred by limitation, highlighting the unjustified delay in recording satisfaction. Considering the statutory limitation period and lapse of time for completing the assessment, the court quashed the assessment orders.
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