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...
Sections 112(a), 112(b) and 114AA are characterised as onerous penalty provisions and require the department to make specific, pointed findings establishing serious violations and an intention to evade duty before imposing penalties; mere reliance on a retracted statement and bills of entry without detailing the petitioner's role, the false declaration attributed to them, or the value misdeclared is inadequate. Confiscation must operate as the predicate for penal liability. The document concludes that the existing order lacks substantive reasoned findings and directs a fresh hearing and a reasoned de novo adjudication with specific charges delineating the petitioner's role.
Sections 112(a), 112(b) and 114AA are characterised as onerous penalty provisions and require the department to make specific, pointed findings establishing serious violations and an intention to evade duty before imposing penalties; mere reliance on a retracted statement and bills of entry without detailing the petitioner's role, the false declaration attributed to them, or the value misdeclared is inadequate. Confiscation must operate as the predicate for penal liability. The document concludes that the existing order lacks substantive reasoned findings and directs a fresh hearing and a reasoned de novo adjudication with specific charges delineating the petitioner's role.
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