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 principal issue was whether penalty orders under section 271E (and 271D) were time-barred under section 275(1)(c). The Tribunal held that section 275(1)(c) requires either expiry of the relevant financial year after assessment or lapse of six months from the end of the month in which the Assessing Officer referred the matter for imposition of penalty; the six-month period is computed from the AO's reference, and the approval or issuance of a show-cause notice by a higher authority is irrelevant. Applying that interpretation, the penalty orders for the assessment years in question were held time-barred and the appeals were allowed. - ITAT
The principal issue was whether penalty orders under section 271E (and 271D) were time-barred under section 275(1)(c). The Tribunal held that section 275(1)(c) requires either expiry of the relevant financial year after assessment or lapse of six months from the end of the month in which the Assessing Officer referred the matter for imposition of penalty; the six-month period is computed from the AO's reference, and the approval or issuance of a show-cause notice by a higher authority is irrelevant. Applying that interpretation, the penalty orders for the assessment years in question were held time-barred and the appeals were allowed. - ITAT
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