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...
Goodwill amortisation was held to be an extraordinary/non operating expense for PLI computation under the TNMM and must be treated as non operating with corresponding adjustment to the PLI when computing ALP; the matter was remanded to AO/TPO only for verification whether depreciation was claimed and for giving the assessee opportunity of hearing. The Tribunal found the lower authorities misconstrued an earlier direction, directed AO/TPO to adjust PLI accordingly, and held initiation of penalty proceedings as premature and dismissed them.
Goodwill amortisation was held to be an extraordinary/non operating expense for PLI computation under the TNMM and must be treated as non operating with corresponding adjustment to the PLI when computing ALP; the matter was remanded to AO/TPO only for verification whether depreciation was claimed and for giving the assessee opportunity of hearing. The Tribunal found the lower authorities misconstrued an earlier direction, directed AO/TPO to adjust PLI accordingly, and held initiation of penalty proceedings as premature and dismissed them.
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