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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Bogus purchase additions based on estimated profit were deleted where the assessee produced GST-linked purchase records, quantitative stock statements, movement details and payment evidence, and none of those books or results were found defective. In the absence of rejection of books or any finding that the disclosed gross profit was unreasonable, an 8% profit estimate on alleged bogus purchases was impermissible. The addition for alleged cessation of liability was also deleted because the ledger balance was supported by invoices and bank payments, and no adverse factual finding displaced that documentary evidence.
Bogus purchase additions based on estimated profit were deleted where the assessee produced GST-linked purchase records, quantitative stock statements, movement details and payment evidence, and none of those books or results were found defective. In the absence of rejection of books or any finding that the disclosed gross profit was unreasonable, an 8% profit estimate on alleged bogus purchases was impermissible. The addition for alleged cessation of liability was also deleted because the ledger balance was supported by invoices and bank payments, and no adverse factual finding displaced that documentary evidence.
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