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...
Reopening of assessment u/s 147 - non independent application of mind by AO - Scope of borrowed satisfaction - The Appellate Tribunal found that the reopening was solely based on assumptions without concrete evidence linking the assessee to the alleged transactions. It was observed that the Assessing Officer did not adequately apply his mind before issuing the notice, and the conclusions were merely a reproduction of the investigation report. Citing precedents, the Tribunal emphasized the necessity of an independent application of mind by the Assessing Officer and concluded that the notice was invalid.
Reopening of assessment u/s 147 - non independent application of mind by AO - Scope of borrowed satisfaction - The Appellate Tribunal found that the reopening was solely based on assumptions without concrete evidence linking the assessee to the alleged transactions. It was observed that the Assessing Officer did not adequately apply his mind before issuing the notice, and the conclusions were merely a reproduction of the investigation report. Citing precedents, the Tribunal emphasized the necessity of an independent application of mind by the Assessing Officer and concluded that the notice was invalid.
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