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...
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Determination of proceeds of crime by calculating excess excavation as wrongful gain is upheld where documentary records and statements establish quantities beyond permitted limits; appellants failed to discharge the statutory onus to show legitimate source, so disclosed returns did not displace the calculation. Property acquired with excess income is treated as proceeds of crime, and where tainted property is not traceable the value of equivalent property (including assets purchased before the offence) may be provisionally attached subject to established safeguards and tests; provisional attachments were therefore confirmed.
Determination of proceeds of crime by calculating excess excavation as wrongful gain is upheld where documentary records and statements establish quantities beyond permitted limits; appellants failed to discharge the statutory onus to show legitimate source, so disclosed returns did not displace the calculation. Property acquired with excess income is treated as proceeds of crime, and where tainted property is not traceable the value of equivalent property (including assets purchased before the offence) may be provisionally attached subject to established safeguards and tests; provisional attachments were therefore confirmed.
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