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...
Reassessment based on Investigation Wing information was sustained where the original return had only been processed under section 143(1), no return was filed in response to notice under section 148, and the recorded reasons showed a live link between identified penny stock transactions and the belief of escapement. The Tribunal held that the assessee could not invoke the procedural objections available after filing a return in response to reopening, and the challenge to jurisdiction failed. On the merits, the section 68 addition on share sale proceeds was deleted because the transactions were disclosed as part of regular share trading business, supported by contract notes, demat and bank records, and no exempt long-term capital gains had been claimed.
Reassessment based on Investigation Wing information was sustained where the original return had only been processed under section 143(1), no return was filed in response to notice under section 148, and the recorded reasons showed a live link between identified penny stock transactions and the belief of escapement. The Tribunal held that the assessee could not invoke the procedural objections available after filing a return in response to reopening, and the challenge to jurisdiction failed. On the merits, the section 68 addition on share sale proceeds was deleted because the transactions were disclosed as part of regular share trading business, supported by contract notes, demat and bank records, and no exempt long-term capital gains had been claimed.
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