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...
The article addresses limitation for passing reassessment orders, holding that a judicial remand prescribing procedural timelines (supply of reasons, opportunity to file and dispose objections, and a brief bar before assessment) does not qualify as a "finding" or "direction" that triggers the extended limitation available where reassessment is made "in consequence of or to give effect to" a court finding or direction. Consequently, extended limitation is not attracted and ordinary limitation rules apply; after computing excluded periods from earlier writ proceedings and the additional statutory extension, the last date to pass reassessment had expired, rendering reassessment time barred and the writ allowed.
The article addresses limitation for passing reassessment orders, holding that a judicial remand prescribing procedural timelines (supply of reasons, opportunity to file and dispose objections, and a brief bar before assessment) does not qualify as a "finding" or "direction" that triggers the extended limitation available where reassessment is made "in consequence of or to give effect to" a court finding or direction. Consequently, extended limitation is not attracted and ordinary limitation rules apply; after computing excluded periods from earlier writ proceedings and the additional statutory extension, the last date to pass reassessment had expired, rendering reassessment time barred and the writ allowed.
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