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...
Dispute concerned additions to income under section 68 and section 56(2)(viib) alleging unexplained large share capital and excessive premium. Tribunal found that notices to lenders were duly issued and acknowledged and that lenders filed confirmations, so the file contained materials establishing the genuineness, identity and creditworthiness of creditors; this factual appreciation led to dismissal of the revenue's appeal. Non-appearance of directors under summons was noted but did not negate the documentary evidence confirming transactions.
Dispute concerned additions to income under section 68 and section 56(2)(viib) alleging unexplained large share capital and excessive premium. Tribunal found that notices to lenders were duly issued and acknowledged and that lenders filed confirmations, so the file contained materials establishing the genuineness, identity and creditworthiness of creditors; this factual appreciation led to dismissal of the revenue's appeal. Non-appearance of directors under summons was noted but did not negate the documentary evidence confirming transactions.
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