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...
Revisionary power under section 263 was examined in relation to a disallowance under section 11 for payments to specified/related persons; ITAT held the revisional authority failed to conduct its own enquiry and improperly remanded the matter for fresh verification, which constitutes an impermissible roving inquiry. The Assessing Officer had sought and considered detailed explanations and documents from the assessee before passing the assessment, and no material demonstrated falsity or discrepancy. Because no prejudice to revenue arose (taxes paid by specified persons and no taxable income in trust), the CIT(E)'s revision was set aside and the assessee's grounds allowed.
Revisionary power under section 263 was examined in relation to a disallowance under section 11 for payments to specified/related persons; ITAT held the revisional authority failed to conduct its own enquiry and improperly remanded the matter for fresh verification, which constitutes an impermissible roving inquiry. The Assessing Officer had sought and considered detailed explanations and documents from the assessee before passing the assessment, and no material demonstrated falsity or discrepancy. Because no prejudice to revenue arose (taxes paid by specified persons and no taxable income in trust), the CIT(E)'s revision was set aside and the assessee's grounds allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
