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...
Limitation on carry forward of capital losses was applied: the Tribunal found the assessee did not rebut the revenue's contention or show entitlement to set off a carry forward capital loss beyond the eight succeeding assessment years in which the loss was first computed, and upheld the disallowance of that setoff. On deductibility, the Tribunal treated interest received on enhanced/delayed compensation as income from other sources and held it deductible under the statutory provision governing interest deductions, setting aside the appellate finding and directing the Assessing Officer to allow the deduction accordingly.
Limitation on carry forward of capital losses was applied: the Tribunal found the assessee did not rebut the revenue's contention or show entitlement to set off a carry forward capital loss beyond the eight succeeding assessment years in which the loss was first computed, and upheld the disallowance of that setoff. On deductibility, the Tribunal treated interest received on enhanced/delayed compensation as income from other sources and held it deductible under the statutory provision governing interest deductions, setting aside the appellate finding and directing the Assessing Officer to allow the deduction accordingly.
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