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 AT held that, following consideration of the DGAP report and documentary verification, the DGAP's methodology for apportioning ITC to project costs was appropriate and captured the economic effect of GST implementation. The Tribunal found that no reduction in GST rate nor incremental benefit of Input Tax Credit accrued to the Respondent in respect of the three impugned projects; accordingly, the requirements of Section 171 of the CGST Act are not attracted. Proceedings against the Respondent in relation to those projects were dismissed and the application disposed of.
The AT held that, following consideration of the DGAP report and documentary verification, the DGAP's methodology for apportioning ITC to project costs was appropriate and captured the economic effect of GST implementation. The Tribunal found that no reduction in GST rate nor incremental benefit of Input Tax Credit accrued to the Respondent in respect of the three impugned projects; accordingly, the requirements of Section 171 of the CGST Act are not attracted. Proceedings against the Respondent in relation to those projects were dismissed and the application disposed of.
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