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 assessee bank made provisions for group gratuity and leave encashment by debiting expenses in its books, but these provisions were never treated as real expenses for income tax purposes. The AO made additions for the difference between the book provisions and actuarial valuations. The ITAT held that the expenses debited pertained to the assessment year and were real expenses, not provisions. The AO's findings that the amounts did not pertain to the year were perverse. Only real income is taxable, not provisions, as held in Shoorji Vallabhdas case. The assessee did not claim notional expenses to reduce profits. The AO's additions were deleted.
The assessee bank made provisions for group gratuity and leave encashment by debiting expenses in its books, but these provisions were never treated as real expenses for income tax purposes. The AO made additions for the difference between the book provisions and actuarial valuations. The ITAT held that the expenses debited pertained to the assessment year and were real expenses, not provisions. The AO's findings that the amounts did not pertain to the year were perverse. Only real income is taxable, not provisions, as held in Shoorji Vallabhdas case. The assessee did not claim notional expenses to reduce profits. The AO's additions were deleted.
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