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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A composite property used partly for residence and partly for commercial activity was treated as eligible for section 54 relief to the extent of the residential portion. The Tribunal held that the residential component could not be ignored merely because the sale agreement described the property as commercial, and directed apportionment of sale consideration relating to the residential floors before granting exemption. On the addition under section 56(2)(vii), it held that where the assessee disputed the stamp valuation, the Assessing Officer should have referred the matter to the DVO instead of directly taxing the difference. The valuation issue was remitted for fresh decision.
A composite property used partly for residence and partly for commercial activity was treated as eligible for section 54 relief to the extent of the residential portion. The Tribunal held that the residential component could not be ignored merely because the sale agreement described the property as commercial, and directed apportionment of sale consideration relating to the residential floors before granting exemption. On the addition under section 56(2)(vii), it held that where the assessee disputed the stamp valuation, the Assessing Officer should have referred the matter to the DVO instead of directly taxing the difference. The valuation issue was remitted for fresh decision.
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