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...
Commission paid to a promoter and full-time working director was held not deductible where the assessee failed to show a direct nexus between the payment and services separate from his ordinary duties. The Tribunal found that his day-to-day involvement in marketing and business development fell within his existing role, and that a turnover-linked commission capped in amount was not justified as an independent business outgo when salary and remuneration were already paid for the same work. Board and shareholder approval was not treated as conclusive, and the disallowance was restored.
Commission paid to a promoter and full-time working director was held not deductible where the assessee failed to show a direct nexus between the payment and services separate from his ordinary duties. The Tribunal found that his day-to-day involvement in marketing and business development fell within his existing role, and that a turnover-linked commission capped in amount was not justified as an independent business outgo when salary and remuneration were already paid for the same work. Board and shareholder approval was not treated as conclusive, and the disallowance was restored.
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