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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Transfer pricing adjustment on AMP expenditure was deleted because the Bright Line Test could not be applied to determine arm's length price, following Delhi High Court and coordinate Bench precedent; the Tribunal held no adjustment was warranted on the assessee's AMP spend. The section 43B issue on bonus payment was not decided on merits and was remitted to verify whether the bonus was paid within the return-filing due date, in which case no addition would arise. Claims relating to short grant of self-assessment tax credit and deduction of interest on VAT duty were also restored for fresh examination. The appeal was thus partly allowed.
Transfer pricing adjustment on AMP expenditure was deleted because the Bright Line Test could not be applied to determine arm's length price, following Delhi High Court and coordinate Bench precedent; the Tribunal held no adjustment was warranted on the assessee's AMP spend. The section 43B issue on bonus payment was not decided on merits and was remitted to verify whether the bonus was paid within the return-filing due date, in which case no addition would arise. Claims relating to short grant of self-assessment tax credit and deduction of interest on VAT duty were also restored for fresh examination. The appeal was thus partly allowed.
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