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...
Disallowance of remuneration to directors and relatives under section 40A(2)(b) was deleted because the Assessing Officer did not benchmark the payment against fair market value and relied instead on an earlier-year comparison and an arbitrary 10% increase, despite accepted past scrutiny assessments and undisputed services. The Tribunal also upheld allowance of foreign travel expenditure, finding no Rule 46A breach where the travel details had already been filed and no evidence showed absence of business purpose. The revenue's appeal was dismissed.
Disallowance of remuneration to directors and relatives under section 40A(2)(b) was deleted because the Assessing Officer did not benchmark the payment against fair market value and relied instead on an earlier-year comparison and an arbitrary 10% increase, despite accepted past scrutiny assessments and undisputed services. The Tribunal also upheld allowance of foreign travel expenditure, finding no Rule 46A breach where the travel details had already been filed and no evidence showed absence of business purpose. The revenue's appeal was dismissed.
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