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...
Deduction under section 10A was allowed as an alternate claim even though the return had originally claimed section 10B, because Form 56F was furnished during assessment and the same units had already been allowed section 10A relief in earlier scrutiny years; in the absence of any material showing those earlier allowances were or revised, the Revenue could not deny eligibility in the later year. The Tribunal also held that the assessee failed to show that the assessment order was without jurisdiction, while the jurisdiction order under section 120 was on record, so the jurisdictional objection had no merit. The Revenue's appeal was rejected and the cross-objection was dismissed.
Deduction under section 10A was allowed as an alternate claim even though the return had originally claimed section 10B, because Form 56F was furnished during assessment and the same units had already been allowed section 10A relief in earlier scrutiny years; in the absence of any material showing those earlier allowances were or revised, the Revenue could not deny eligibility in the later year. The Tribunal also held that the assessee failed to show that the assessment order was without jurisdiction, while the jurisdiction order under section 120 was on record, so the jurisdictional objection had no merit. The Revenue's appeal was rejected and the cross-objection was dismissed.
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