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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Section 142A permits a reference to the Valuation Officer only in the course of making an assessment or reassessment, and only where the Assessing Officer has material showing that the assessee's valuation is unreliable. The provision cannot be used to collect information for reopening assessment. Where the books of account are neither rejected nor found defective, the Assessing Officer cannot rely solely on the DVO's report to make additions. On these facts, the valuation reference made during reopening, and the additions based on it, were held unsustainable, and the Tribunal's order was affirmed.
Section 142A permits a reference to the Valuation Officer only in the course of making an assessment or reassessment, and only where the Assessing Officer has material showing that the assessee's valuation is unreliable. The provision cannot be used to collect information for reopening assessment. Where the books of account are neither rejected nor found defective, the Assessing Officer cannot rely solely on the DVO's report to make additions. On these facts, the valuation reference made during reopening, and the additions based on it, were held unsustainable, and the Tribunal's order was affirmed.
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