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...
Hybrid seed production on leased agricultural land was treated as agricultural income because the assessee had exclusive use and beneficial control of the land, supervised cultivation, bore the cultivation risk, and owned the produce; use of technical methods did not change the agricultural character, so the addition as business income was deleted. Trade creditors for professional and compliance expenses were held outside section 68 because they were not loan credits and were later paid through banking channels, so that addition was deleted. Balance differences in creditor confirmations were not taxable under section 69C or section 41(1) absent proof of remission or cessation of liability, so that addition was also deleted.
Hybrid seed production on leased agricultural land was treated as agricultural income because the assessee had exclusive use and beneficial control of the land, supervised cultivation, bore the cultivation risk, and owned the produce; use of technical methods did not change the agricultural character, so the addition as business income was deleted. Trade creditors for professional and compliance expenses were held outside section 68 because they were not loan credits and were later paid through banking channels, so that addition was deleted. Balance differences in creditor confirmations were not taxable under section 69C or section 41(1) absent proof of remission or cessation of liability, so that addition was also deleted.
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