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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Penalty under section 271(1)(c) could not be sustained where the disallowance arose from a debatable claim for proportionate amortisation of lease premium and the jurisdictional High Court had already admitted a substantial question of law in the assessee's own case. The Tribunal held that the claim was bona fide and, following Reliance Petroproducts, mere making of an unsustainable claim did not amount to furnishing inaccurate particulars absent any finding that the particulars were false or erroneous. On that basis, the penalty for both assessment years was quashed.
Penalty under section 271(1)(c) could not be sustained where the disallowance arose from a debatable claim for proportionate amortisation of lease premium and the jurisdictional High Court had already admitted a substantial question of law in the assessee's own case. The Tribunal held that the claim was bona fide and, following Reliance Petroproducts, mere making of an unsustainable claim did not amount to furnishing inaccurate particulars absent any finding that the particulars were false or erroneous. On that basis, the penalty for both assessment years was quashed.
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