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...
A seized photocopy of an agreement to sell was treated as reliable incriminating material where it was signed on every page, witnessed, and matched the subsequent registered sale deeds on consideration details, cheque particulars and witness identity; the Tribunal held that no further independent corroboration was required and sustained the addition for under-reported sale consideration. For penalty, it held that cash paid at the time of execution of a registered sale deed is distinct from the advance or specified sum targeted by the amended section 269SS, which was intended to curb cash advances in real-estate transactions; on that basis, penalty under section 271D was deleted.
A seized photocopy of an agreement to sell was treated as reliable incriminating material where it was signed on every page, witnessed, and matched the subsequent registered sale deeds on consideration details, cheque particulars and witness identity; the Tribunal held that no further independent corroboration was required and sustained the addition for under-reported sale consideration. For penalty, it held that cash paid at the time of execution of a registered sale deed is distinct from the advance or specified sum targeted by the amended section 269SS, which was intended to curb cash advances in real-estate transactions; on that basis, penalty under section 271D was deleted.
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