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 HC allowed the writ petition, holding that the AO possessed sufficient material to initiate reassessment proceedings under s.148 read with s.148A(1) and to frame an order under s.143A(3); the impugned action was taken pursuant to information generated under the CBDT's Risk Management Strategy recognised by s.148(3)(i). The court rejected the AO's inference that liquidation of a counterparty (hereinafter "Entity X") amounted to proof of a bogus concern, noting that subsequent acquisition of Entity X evidenced commercial legitimacy and that liquidation alone cannot justify a presumption of sham transactions. It was also noted that no complaint of denial of hearing under s.148A(1) was made.
The HC allowed the writ petition, holding that the AO possessed sufficient material to initiate reassessment proceedings under s.148 read with s.148A(1) and to frame an order under s.143A(3); the impugned action was taken pursuant to information generated under the CBDT's Risk Management Strategy recognised by s.148(3)(i). The court rejected the AO's inference that liquidation of a counterparty (hereinafter "Entity X") amounted to proof of a bogus concern, noting that subsequent acquisition of Entity X evidenced commercial legitimacy and that liquidation alone cannot justify a presumption of sham transactions. It was also noted that no complaint of denial of hearing under s.148A(1) was made.
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