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...
Where liability to incur construction expenditure had already accrued under the business transaction, the Court applied the mercantile system and the Calcutta Company principle to allow deduction of the estimated expense on accrual basis; the concurrent finding permitting the construction deduction was upheld. In the sale-and-lease-back arrangement involving cinematographic rights, title had passed to the assessee and the vendor thereafter remained only as lessee; mere tax-saving motive, unsupported by material, did not make the transaction a colourable device. Depreciation on the films was therefore allowed, and the Revenue failed on both issues.
Where liability to incur construction expenditure had already accrued under the business transaction, the Court applied the mercantile system and the Calcutta Company principle to allow deduction of the estimated expense on accrual basis; the concurrent finding permitting the construction deduction was upheld. In the sale-and-lease-back arrangement involving cinematographic rights, title had passed to the assessee and the vendor thereafter remained only as lessee; mere tax-saving motive, unsupported by material, did not make the transaction a colourable device. Depreciation on the films was therefore allowed, and the Revenue failed on both issues.
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