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...
CENVAT credit distributed through ISD invoices remained subject to merits review, so the recipient unit could be proceeded against and was not immune merely because the credit originated from an ISD. On outward transportation, admissibility depended on the place of removal: where contractual terms showed that delivery, installation, commissioning and acceptance at the buyer's premises completed the sale, that premises was treated as the place of removal and transportation up to that point was eligible in principle. The extended period was unavailable because the dispute was interpretational, statutory records were filed, and no wilful suppression or intent to evade was shown. The demand, interest and penalty were therefore time-barred and unsustainable.
CENVAT credit distributed through ISD invoices remained subject to merits review, so the recipient unit could be proceeded against and was not immune merely because the credit originated from an ISD. On outward transportation, admissibility depended on the place of removal: where contractual terms showed that delivery, installation, commissioning and acceptance at the buyer's premises completed the sale, that premises was treated as the place of removal and transportation up to that point was eligible in principle. The extended period was unavailable because the dispute was interpretational, statutory records were filed, and no wilful suppression or intent to evade was shown. The demand, interest and penalty were therefore time-barred and unsustainable.
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