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...
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Invalid approval for reassessment under the post-search regime vitiated the assessments, because the record did not show proper transmission of seized material to the approving authority and that factual gap remained unrebutted. The Tribunal also treated the assessments for the relevant years as wrongly framed under section 143(3), since after the search they fell within the post-search reassessment framework under sections 148/147, and quashed them on that basis. On the property issue, it accepted the seized document showing a lower investment figure and reduced the unexplained investment addition accordingly. On the cash issue, it directed verification of the company's taxed income and grant of telescoping to prevent double addition.
Invalid approval for reassessment under the post-search regime vitiated the assessments, because the record did not show proper transmission of seized material to the approving authority and that factual gap remained unrebutted. The Tribunal also treated the assessments for the relevant years as wrongly framed under section 143(3), since after the search they fell within the post-search reassessment framework under sections 148/147, and quashed them on that basis. On the property issue, it accepted the seized document showing a lower investment figure and reduced the unexplained investment addition accordingly. On the cash issue, it directed verification of the company's taxed income and grant of telescoping to prevent double addition.
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