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...
Omission of section 92BA(1) without a saving clause rendered the provision nonexistent, therefore any assessment officer reference to the transfer pricing officer to determine the arm's length price of specified domestic transactions lacked jurisdiction and the TPO's consequential order was invalid; the appellate authority has deleted the additions and the revenue appeal was dismissed, applying the principle that where a statutory provision is omitted from the statute book the AO cannot invoke that provision to re open or adjust domestic transfer pricing.
Omission of section 92BA(1) without a saving clause rendered the provision nonexistent, therefore any assessment officer reference to the transfer pricing officer to determine the arm's length price of specified domestic transactions lacked jurisdiction and the TPO's consequential order was invalid; the appellate authority has deleted the additions and the revenue appeal was dismissed, applying the principle that where a statutory provision is omitted from the statute book the AO cannot invoke that provision to re open or adjust domestic transfer pricing.
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