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...
Tribunal power to admit belated additional grounds was upheld where those grounds go to the root of the dispute and all relevant facts are already on record; accordingly the tribunal admitted the assessee's additional ground. Reopening of assessment was held invalid because the reassessment was initiated solely on specified cash deposits yet the assessing officer made an unrelated addition by disallowing an exemption that was not part of the recorded reasons for reopening; since the addition did not flow from the recorded reasons, the reopening was quashed and the appeal allowed.
Tribunal power to admit belated additional grounds was upheld where those grounds go to the root of the dispute and all relevant facts are already on record; accordingly the tribunal admitted the assessee's additional ground. Reopening of assessment was held invalid because the reassessment was initiated solely on specified cash deposits yet the assessing officer made an unrelated addition by disallowing an exemption that was not part of the recorded reasons for reopening; since the addition did not flow from the recorded reasons, the reopening was quashed and the appeal allowed.
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