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 Tribunal examined multiple search-related assessment issues, including section 68 cash credits, section 69C unexplained expenditure, bogus purchases, stock discrepancy, employees' contribution disallowance, and section 153A jurisdiction. It held that primary evidence such as confirmations, PAN, returns and bank statements was sufficient for section 68, and the Revenue had to conduct independent verification; the source of source was not required on these facts. It also sustained only the profit element in disputed purchases, deleted a stock-difference addition after reconciliation and valuation defects, remanded one seized-noting issue for fresh verification, upheld disallowance of delayed employees' contribution, and rejected the challenge to assessments based on seized material.
The Tribunal examined multiple search-related assessment issues, including section 68 cash credits, section 69C unexplained expenditure, bogus purchases, stock discrepancy, employees' contribution disallowance, and section 153A jurisdiction. It held that primary evidence such as confirmations, PAN, returns and bank statements was sufficient for section 68, and the Revenue had to conduct independent verification; the source of source was not required on these facts. It also sustained only the profit element in disputed purchases, deleted a stock-difference addition after reconciliation and valuation defects, remanded one seized-noting issue for fresh verification, upheld disallowance of delayed employees' contribution, and rejected the challenge to assessments based on seized material.
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