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...
The ITAT Kolkata examined the validity of reassessment proceedings based on "reasons to believe" u/s 147. The AO's reasons lacked independent application of mind, being based on borrowed satisfaction without proper enquiry. The AO noted discrepancies in LTCG disclosure and re-assessed income u/s 147. However, the Tribunal found the AO's actions flawed, as the assessee had disclosed exempt income in Schedule-EI. The AO's lack of independent satisfaction led to quashing of the assessment, citing Meenakshi Overseas (P) Ltd. The appeal of the assessee was allowed.
The ITAT Kolkata examined the validity of reassessment proceedings based on "reasons to believe" u/s 147. The AO's reasons lacked independent application of mind, being based on borrowed satisfaction without proper enquiry. The AO noted discrepancies in LTCG disclosure and re-assessed income u/s 147. However, the Tribunal found the AO's actions flawed, as the assessee had disclosed exempt income in Schedule-EI. The AO's lack of independent satisfaction led to quashing of the assessment, citing Meenakshi Overseas (P) Ltd. The appeal of the assessee was allowed.
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