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...
After admitting an additional ground for deduction under section 32AC, the ITAT held that the appellate authority had to decide the claim on merits and could not refuse it merely because it was raised belatedly or on conduct-based objections already waived at admission. It further held that Goetz India Ltd. did not limit the appellate authority's power to entertain a fresh statutory claim supported by documents and capable of verification. However, because the remand report did not clearly confirm that the assets were new plant and machinery or that all statutory conditions were met, the matter was remanded to the Assessing Officer for fresh examination.
After admitting an additional ground for deduction under section 32AC, the ITAT held that the appellate authority had to decide the claim on merits and could not refuse it merely because it was raised belatedly or on conduct-based objections already waived at admission. It further held that Goetz India Ltd. did not limit the appellate authority's power to entertain a fresh statutory claim supported by documents and capable of verification. However, because the remand report did not clearly confirm that the assets were new plant and machinery or that all statutory conditions were met, the matter was remanded to the Assessing Officer for fresh examination.
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