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...
Reassessment proceedings were held to be within limitation because the first corrigendum to the section 148A(b) notice validly extended the time to respond, and that extended period had to be excluded under the third proviso to section 149(1). On that basis, the section 148A(d) order and section 148 notice were timely, and approval by the PCIT/CIT was competent rather than approval by the PCCIT/CCIT. The objection that only the Faceless Assessing Officer could issue the notice was rejected, as both the jurisdictional and faceless officers were treated as competent. The writ challenge on disputed factual issues, including claimed tax exemption and NRE account status, was not entertained, leaving those matters for the Assessing Officer.
Reassessment proceedings were held to be within limitation because the first corrigendum to the section 148A(b) notice validly extended the time to respond, and that extended period had to be excluded under the third proviso to section 149(1). On that basis, the section 148A(d) order and section 148 notice were timely, and approval by the PCIT/CIT was competent rather than approval by the PCCIT/CCIT. The objection that only the Faceless Assessing Officer could issue the notice was rejected, as both the jurisdictional and faceless officers were treated as competent. The writ challenge on disputed factual issues, including claimed tax exemption and NRE account status, was not entertained, leaving those matters for the Assessing Officer.
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