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...
The Tribunal upheld provisional attachment of property under Section 24(4)(b)(i), holding that the provision permits protective attachment with prior approval and does not require an additional pre-attachment show-cause notice where no prior attachment exists under Section 24(3). It also accepted the department's case that routed funds, accommodation entries, bogus security premium, capital, loans and income heads disclosed a benami arrangement through layered transactions, and rejected the view that connected beneficial ownership defeated the charge. Acquittal or discharge in criminal proceedings was held not determinative in benami proceedings, which apply a different standard. The impugned adjudication was set aside as perverse and contradictory, and the appeals were allowed.
The Tribunal upheld provisional attachment of property under Section 24(4)(b)(i), holding that the provision permits protective attachment with prior approval and does not require an additional pre-attachment show-cause notice where no prior attachment exists under Section 24(3). It also accepted the department's case that routed funds, accommodation entries, bogus security premium, capital, loans and income heads disclosed a benami arrangement through layered transactions, and rejected the view that connected beneficial ownership defeated the charge. Acquittal or discharge in criminal proceedings was held not determinative in benami proceedings, which apply a different standard. The impugned adjudication was set aside as perverse and contradictory, and the appeals were allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
