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...
Undisclosed receipts were added to gross profit by the AO, but the assessee claimed corresponding expenditure. CIT(A) deleted the addition, terming it double assessment. The department did not rebut that the addition was double assessment or deny the corresponding expenditure. ITAT held that the AO could not brush aside the assessee's claim of corresponding expenditure, which was duly considered by CIT(A). The department's grounds did not dispute the correctness of the expenditure items. The addition was rejected accordingly.
Undisclosed receipts were added to gross profit by the AO, but the assessee claimed corresponding expenditure. CIT(A) deleted the addition, terming it double assessment. The department did not rebut that the addition was double assessment or deny the corresponding expenditure. ITAT held that the AO could not brush aside the assessee's claim of corresponding expenditure, which was duly considered by CIT(A). The department's grounds did not dispute the correctness of the expenditure items. The addition was rejected accordingly.
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