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...
After the assessee filed a return in response to notice under section 148, the ITAT held that issuance of notice under section 143(2) was mandatory before completing reassessment to the assessee's detriment. The Tribunal treated the omission as a jurisdictional defect, not a curable procedural irregularity, and held that section 292BB cannot cure the complete absence of notice, only defects in service where notice has already been issued. Since no section 143(2) notice was issued after the return was filed and acted upon, the reassessment order was annulled.
After the assessee filed a return in response to notice under section 148, the ITAT held that issuance of notice under section 143(2) was mandatory before completing reassessment to the assessee's detriment. The Tribunal treated the omission as a jurisdictional defect, not a curable procedural irregularity, and held that section 292BB cannot cure the complete absence of notice, only defects in service where notice has already been issued. Since no section 143(2) notice was issued after the return was filed and acted upon, the reassessment order was annulled.
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