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...
Provisional attachment of the property was confirmed under the PBPT Act as the transaction falls within the scope of benami property under Section 2(9)(A); the appellant failed to explain sources of funds, did not produce original lease evidence and adverse inference was drawn for non-production, supporting IO findings of fabrication. Beneficial ownership remains under investigation-IO to re-investigate whether the beneficial owner includes the named individual, his son, and/or a company-so the property is not to be released. The Tribunal may modify AA orders under Section 46(4)(e); appeal by the benamidar is dismissed.
Provisional attachment of the property was confirmed under the PBPT Act as the transaction falls within the scope of benami property under Section 2(9)(A); the appellant failed to explain sources of funds, did not produce original lease evidence and adverse inference was drawn for non-production, supporting IO findings of fabrication. Beneficial ownership remains under investigation-IO to re-investigate whether the beneficial owner includes the named individual, his son, and/or a company-so the property is not to be released. The Tribunal may modify AA orders under Section 46(4)(e); appeal by the benamidar is dismissed.
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