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...
Reopening of assessment under Section 147/148 was invalid where it relied on documents seized from a third party; the special procedure for seized material belonging to persons other than the searched party under Section 153C read with Section 153A applies and has overriding effect. The Tribunal followed higher court and coordinate ITAT decisions interpreting the non obstante clause to require AO to proceed under the special procedure; because the AO abandoned 153C proceedings and issued a Section 148 notice, the reassessment and resulting assessment were quashed as void ab initio.
Reopening of assessment under Section 147/148 was invalid where it relied on documents seized from a third party; the special procedure for seized material belonging to persons other than the searched party under Section 153C read with Section 153A applies and has overriding effect. The Tribunal followed higher court and coordinate ITAT decisions interpreting the non obstante clause to require AO to proceed under the special procedure; because the AO abandoned 153C proceedings and issued a Section 148 notice, the reassessment and resulting assessment were quashed as void ab initio.
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