Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Deposits made by assessee in Krishi Bank were fixed deposit investments, not trading activity. Loss suffered when bank went into liquidation is capital loss, not business loss u/s 28 or bad debt u/s 36(1)(vii). Assessing Officer and appellate authorities rightly treated loss as capital loss based on evidence. No substantial question of law arises for adjudication u/s 260A as it involves findings of fact which cannot be re-adjudicated in appeal. Substantial question of law answered against assessee in favor of revenue.
Deposits made by assessee in Krishi Bank were fixed deposit investments, not trading activity. Loss suffered when bank went into liquidation is capital loss, not business loss u/s 28 or bad debt u/s 36(1)(vii). Assessing Officer and appellate authorities rightly treated loss as capital loss based on evidence. No substantial question of law arises for adjudication u/s 260A as it involves findings of fact which cannot be re-adjudicated in appeal. Substantial question of law answered against assessee in favor of revenue.
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