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...
Where an assessing officer treated an amount shown as outstanding in the assessee's balance-sheet as unexplained income, the Tribunal accepted that bank account statements and TDS challans (including TDS payment with interest and late fee) evidencing subsequent payment sufficiently established the outstanding liability; the sale deeds' recital of full receipt without recording mode of payment did not override documentary banking evidence. On that basis the Tribunal held the Section 69A addition unsustainable and deleted the addition, allowing the assessee's appeal for the relevant assessment year.
Where an assessing officer treated an amount shown as outstanding in the assessee's balance-sheet as unexplained income, the Tribunal accepted that bank account statements and TDS challans (including TDS payment with interest and late fee) evidencing subsequent payment sufficiently established the outstanding liability; the sale deeds' recital of full receipt without recording mode of payment did not override documentary banking evidence. On that basis the Tribunal held the Section 69A addition unsustainable and deleted the addition, allowing the assessee's appeal for the relevant assessment year.
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