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 ITAT held that the intimation under section 143(1) issued on 30.03.2019 was invalid as it was passed before the expiry of the mandatory 30-day period provided to the assessee for submitting a response, which ended on 22.04.2019. The purported response date of 23.03.2019 was found to be incorrect and inconsistent with the record. Consequently, the Tribunal ruled that the intimation was bad in law for non-compliance with the statutory procedural requirement. As a result, the disallowance made by the AO pursuant to the impugned intimation was deleted. The appeal filed by the assessee was allowed.
The ITAT held that the intimation under section 143(1) issued on 30.03.2019 was invalid as it was passed before the expiry of the mandatory 30-day period provided to the assessee for submitting a response, which ended on 22.04.2019. The purported response date of 23.03.2019 was found to be incorrect and inconsistent with the record. Consequently, the Tribunal ruled that the intimation was bad in law for non-compliance with the statutory procedural requirement. As a result, the disallowance made by the AO pursuant to the impugned intimation was deleted. The appeal filed by the assessee was allowed.
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