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...
Leased premises used as a hotel, though containing a restaurant, banquet and conference halls, bar and health club, qualify as a building used for accommodation and thus fall within the renting of immovable property exclusion; the Tribunal found those facilities to be integral or incidental to hotel activity rather than separate commercial deployments and held that Explanation 2 deeming partial business use is not attracted. Applying the plain-text exclusion and following prior coordinate-bench reasoning affirmed by higher authority, the impugned demand and orders were set aside with consequential relief.
Leased premises used as a hotel, though containing a restaurant, banquet and conference halls, bar and health club, qualify as a building used for accommodation and thus fall within the renting of immovable property exclusion; the Tribunal found those facilities to be integral or incidental to hotel activity rather than separate commercial deployments and held that Explanation 2 deeming partial business use is not attracted. Applying the plain-text exclusion and following prior coordinate-bench reasoning affirmed by higher authority, the impugned demand and orders were set aside with consequential relief.
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