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...
AO reopened assessment beyond 4 year period without establishing assessee failed to truly disclose material facts. ITAT quashed reopening, holding AO merely changed opinion without tangible belief of escaped income. PCIT's revision u/s 263 to assess other income was rejected as show-cause didn't specify impugned order date, making action time-barred. Further, PCIT couldn't conclude assessment erroneous for non-consideration of information already possessed by AO while forming reopening belief. Assessee's appeal allowed by ITAT.
AO reopened assessment beyond 4 year period without establishing assessee failed to truly disclose material facts. ITAT quashed reopening, holding AO merely changed opinion without tangible belief of escaped income. PCIT's revision u/s 263 to assess other income was rejected as show-cause didn't specify impugned order date, making action time-barred. Further, PCIT couldn't conclude assessment erroneous for non-consideration of information already possessed by AO while forming reopening belief. Assessee's appeal allowed by ITAT.
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