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 High Court considered a Revision u/s 264 where the CIT rejected the application due to delay, stating u/s 143(1) intimation was not revisable. The court declined to condone the delay, noting the tax department's inability to reassess due to limitation provisions. The appellant had initially declared profits as capital gains for certain years, benefiting from lower tax rates. The revenue's change in treating the profits as business income led to the revision petitions. The court found the delay unjustifiable, as the appellant waited until after the Appellate Authority's decision to file the revision petitions. Condoning the delay would unfairly advantage the appellant over the revenue. The Writ Appeal was dismissed in line with the Single Judge's decision.
The High Court considered a Revision u/s 264 where the CIT rejected the application due to delay, stating u/s 143(1) intimation was not revisable. The court declined to condone the delay, noting the tax department's inability to reassess due to limitation provisions. The appellant had initially declared profits as capital gains for certain years, benefiting from lower tax rates. The revenue's change in treating the profits as business income led to the revision petitions. The court found the delay unjustifiable, as the appellant waited until after the Appellate Authority's decision to file the revision petitions. Condoning the delay would unfairly advantage the appellant over the revenue. The Writ Appeal was dismissed in line with the Single Judge's decision.
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