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...
CIT(A)'s power u/s 251(1) restricted to subject matter assessed by AO. Addition for personal withdrawals not allowed as beyond AO's assessment. Addition for drawings from earlier year upheld as correctly reflected in capital account. Interest expenditure disallowance u/s 57(iii) deleted following coordinate bench ruling allowing deduction having nexus with dividend income. AO directed to recompute interest u/s 234B per earlier ITAT order.
CIT(A)'s power u/s 251(1) restricted to subject matter assessed by AO. Addition for personal withdrawals not allowed as beyond AO's assessment. Addition for drawings from earlier year upheld as correctly reflected in capital account. Interest expenditure disallowance u/s 57(iii) deleted following coordinate bench ruling allowing deduction having nexus with dividend income. AO directed to recompute interest u/s 234B per earlier ITAT order.
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