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...
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The ITAT Indore ruled on the validity of reopening assessment u/s 147 based on information from DDIT (Inv.)-Unit 2(2), Kolkata alleging sham transactions with a shell company. Assessee consistently denied such transactions. Tribunal found no evidence of transactions with the alleged shell company, rendering the reassessment invalid. The AO cannot make new additions unrelated to original reasons u/s 147. The 3rd Proviso restricts AO to reassess only matters not subject to appeal, reference, or revision. Relying on Jet Airways case, the reassessment order was quashed, and the assessee succeeded in the appeal.
The ITAT Indore ruled on the validity of reopening assessment u/s 147 based on information from DDIT (Inv.)-Unit 2(2), Kolkata alleging sham transactions with a shell company. Assessee consistently denied such transactions. Tribunal found no evidence of transactions with the alleged shell company, rendering the reassessment invalid. The AO cannot make new additions unrelated to original reasons u/s 147. The 3rd Proviso restricts AO to reassess only matters not subject to appeal, reference, or revision. Relying on Jet Airways case, the reassessment order was quashed, and the assessee succeeded in the appeal.
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