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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Rental receipts from the assessee's property were held to retain the character of income from house property because the assessee had consistently offered them under that head in earlier scrutiny assessments and the Revenue gave no basis to treat them as business income; deduction under section 24(a) was therefore allowed. The Tribunal also held that expenditure on renovation and erection of a temporary office structure, supported by bills and vouchers, was incurred to facilitate business more efficiently and was not shown to create an enduring capital asset; depreciation on the temporary structure was accordingly allowable.
Rental receipts from the assessee's property were held to retain the character of income from house property because the assessee had consistently offered them under that head in earlier scrutiny assessments and the Revenue gave no basis to treat them as business income; deduction under section 24(a) was therefore allowed. The Tribunal also held that expenditure on renovation and erection of a temporary office structure, supported by bills and vouchers, was incurred to facilitate business more efficiently and was not shown to create an enduring capital asset; depreciation on the temporary structure was accordingly allowable.
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