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...
Rectification under section 154 cannot be used to reopen a claim on surcharge and education cess under the India-USA DTAA once the issue has already been decided in a speaking appellate order. The Tribunal held that this was not a mistake apparent from the record, because section 154 does not permit reappreciation or modification of a concluded issue. It also noted that the jurisdictional High Court had taken the same view against the assessee. The rectification order was therefore upheld and the assessee's challenge failed.
Rectification under section 154 cannot be used to reopen a claim on surcharge and education cess under the India-USA DTAA once the issue has already been decided in a speaking appellate order. The Tribunal held that this was not a mistake apparent from the record, because section 154 does not permit reappreciation or modification of a concluded issue. It also noted that the jurisdictional High Court had taken the same view against the assessee. The rectification order was therefore upheld and the assessee's challenge failed.
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