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...
When a registered charitable trust disclosed receipts under "income from other sources," denial of exemption was unwarranted because assessing authorities must apply a judicious approach and grant exemptions or deductions to which the assessee is entitled; appellate authorities are empowered and obligated to correct AO errors and may entertain reliefs not claimed in the return, with supporting precedents and administrative guidance cited. The failure of the AO, CIT(A) and Tribunal to consider merits resulted in reversal of the adverse outcome and payment of costs against the revenue, restoring the trust's entitlement to the claimed exemption.
When a registered charitable trust disclosed receipts under "income from other sources," denial of exemption was unwarranted because assessing authorities must apply a judicious approach and grant exemptions or deductions to which the assessee is entitled; appellate authorities are empowered and obligated to correct AO errors and may entertain reliefs not claimed in the return, with supporting precedents and administrative guidance cited. The failure of the AO, CIT(A) and Tribunal to consider merits resulted in reversal of the adverse outcome and payment of costs against the revenue, restoring the trust's entitlement to the claimed exemption.
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