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 Government company wholly controlled by the State Government through the Governor, with power to appoint and remove directors, was treated as eligible for exemption under section 10(26B) on the basis of its incorporation documents and memorandum and articles of association. The Tribunal followed the co-ordinate bench view in the assessee's own case and accepted that the company was established by the State, so its income was exempt. As the Revenue did not dispute the foundational facts and only raised res judicata, the Tribunal found no error in deleting the additions as non-taxable and upheld the exemption.
A Government company wholly controlled by the State Government through the Governor, with power to appoint and remove directors, was treated as eligible for exemption under section 10(26B) on the basis of its incorporation documents and memorandum and articles of association. The Tribunal followed the co-ordinate bench view in the assessee's own case and accepted that the company was established by the State, so its income was exempt. As the Revenue did not dispute the foundational facts and only raised res judicata, the Tribunal found no error in deleting the additions as non-taxable and upheld the exemption.
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