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...
In search assessment under section 153A, an estimated commission addition was unsustainable because only copies of registered sale deeds were found, and no incriminating material showed brokerage activity or receipt of commission; the Tribunal held the addition was based only on assumption and presumption and affirmed its deletion. A protective addition for alleged cash expenditure also failed because the seized documents were owned up by another person, supported by affidavit, and had already been considered in settlement proceedings; once no further addition was called for on those documents, the protective basis disappeared. The Tribunal dismissed the Revenue's appeal and upheld deletion of both additions.
In search assessment under section 153A, an estimated commission addition was unsustainable because only copies of registered sale deeds were found, and no incriminating material showed brokerage activity or receipt of commission; the Tribunal held the addition was based only on assumption and presumption and affirmed its deletion. A protective addition for alleged cash expenditure also failed because the seized documents were owned up by another person, supported by affidavit, and had already been considered in settlement proceedings; once no further addition was called for on those documents, the protective basis disappeared. The Tribunal dismissed the Revenue's appeal and upheld deletion of both additions.
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