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...
Section 153C proceedings were held time-barred because the satisfaction note relating to the searched person had not been recorded immediately after completion of that person's assessment. Applying Calcutta Knitwears, the Court held that "immediately" means at once after completion of the searched person's assessment, not merely within a reasonable time, and that the relevant delay is measured from that completion date. A delay of about 21 months was found incapable of satisfying the statutory requirement. The notices issued under section 153C, together with the consequential notices and orders, were quashed as unsustainable in law.
Section 153C proceedings were held time-barred because the satisfaction note relating to the searched person had not been recorded immediately after completion of that person's assessment. Applying Calcutta Knitwears, the Court held that "immediately" means at once after completion of the searched person's assessment, not merely within a reasonable time, and that the relevant delay is measured from that completion date. A delay of about 21 months was found incapable of satisfying the statutory requirement. The notices issued under section 153C, together with the consequential notices and orders, were quashed as unsustainable in law.
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