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...
For limitation under section 275(1)(c), the relevant starting point was the date on which the AO recommended initiation of penalty proceedings to the competent authority; the Tribunal treated 11/09/2015 as that date and held that the outer time-limit expired on 31/03/2016. Because the penalty order under section 271C was passed on 19/04/2016, it was time-barred and could not be sustained. The Tribunal therefore quashed the penalty order.
For limitation under section 275(1)(c), the relevant starting point was the date on which the AO recommended initiation of penalty proceedings to the competent authority; the Tribunal treated 11/09/2015 as that date and held that the outer time-limit expired on 31/03/2016. Because the penalty order under section 271C was passed on 19/04/2016, it was time-barred and could not be sustained. The Tribunal therefore quashed the penalty order.
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