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...
Treatment of unaccounted investment in immovable property turned on whether a bank valuation report constituted incriminating material in a search assessment; appellate authority found no incriminating material and sustained deletion of additions disallowing reliance on that valuation. Separate STCG adjustment based on AO's adoption of the DVO estimate at 120% (20% escalation) was held to be a baseless simplicitor estimation; the appellate authority rejected the enhanced valuation and deleted the STCG addition accordingly.
Treatment of unaccounted investment in immovable property turned on whether a bank valuation report constituted incriminating material in a search assessment; appellate authority found no incriminating material and sustained deletion of additions disallowing reliance on that valuation. Separate STCG adjustment based on AO's adoption of the DVO estimate at 120% (20% escalation) was held to be a baseless simplicitor estimation; the appellate authority rejected the enhanced valuation and deleted the STCG addition accordingly.
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