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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An assessment or transfer pricing order passed in the name of a dissolved amalgamating company is void ab initio when the successor entity had already informed the tax authorities of the amalgamation and furnished the NCLT-approved scheme. Applying Maruti Suzuki India Ltd., the ITAT held that such an error is not a curable procedural defect under section 292B. The transfer pricing order, draft assessment order and final assessment order, all issued after dissolution in the name and PAN of the non-existent company, were therefore bad in law.
An assessment or transfer pricing order passed in the name of a dissolved amalgamating company is void ab initio when the successor entity had already informed the tax authorities of the amalgamation and furnished the NCLT-approved scheme. Applying Maruti Suzuki India Ltd., the ITAT held that such an error is not a curable procedural defect under section 292B. The transfer pricing order, draft assessment order and final assessment order, all issued after dissolution in the name and PAN of the non-existent company, were therefore bad in law.
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