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...
Prior intimation under the first proviso to section 143(1)(a) is mandatory before making a proposed adjustment to deny a claimed concessional tax rate under section 115BAB. Where the CPC disallowed the concessional rate and applied the normal rate without first issuing intimation and considering the assessee's response, the adjustment was treated as invalid in law. The Tribunal also noted that, because the statutory time limit for issuing a fresh intimation had expired for the relevant assessment year, no liberty could be granted to restart the processing. The consequential intimation, rectification order, and appellate order were set aside.
Prior intimation under the first proviso to section 143(1)(a) is mandatory before making a proposed adjustment to deny a claimed concessional tax rate under section 115BAB. Where the CPC disallowed the concessional rate and applied the normal rate without first issuing intimation and considering the assessee's response, the adjustment was treated as invalid in law. The Tribunal also noted that, because the statutory time limit for issuing a fresh intimation had expired for the relevant assessment year, no liberty could be granted to restart the processing. The consequential intimation, rectification order, and appellate order were set aside.
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