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...
Penalty under section 271DA for alleged contravention of section 269ST was held time-barred because the limitation under section 275(1)(c) runs from the end of May 2023 and the penalty order issued in September 2024 exceeded that six month period. On merits, consolidated entries in a group-level excel sheet and an uncorroborated confessional statement were held insufficient to prove clause (b) violations of section 269ST for individual sales of spent solvents and scraps; assessment findings alone cannot substitute for independent corroborative evidence in penalty proceedings. Penalty therefore unsustainable on limitation and evidentiary grounds.
Penalty under section 271DA for alleged contravention of section 269ST was held time-barred because the limitation under section 275(1)(c) runs from the end of May 2023 and the penalty order issued in September 2024 exceeded that six month period. On merits, consolidated entries in a group-level excel sheet and an uncorroborated confessional statement were held insufficient to prove clause (b) violations of section 269ST for individual sales of spent solvents and scraps; assessment findings alone cannot substitute for independent corroborative evidence in penalty proceedings. Penalty therefore unsustainable on limitation and evidentiary grounds.
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