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...
The Tribunal upheld deletion of section 68 additions for unsecured loans because the assessee produced confirmations, ledger accounts, income-tax returns, financial statements and bank statements showing identity, creditworthiness and genuineness, with receipts routed through banking channels and no rebuttal by the Revenue. It also accepted telescoping where the cash used for cheque-against-cash entries was linked to an already taxed on-money stream, so the related principal and interest additions did not survive. On disallowance of interest for diversion of borrowed funds, the Tribunal sustained only the reduced amount after finding no error in the appellate working of interest-free funds and advances.
The Tribunal upheld deletion of section 68 additions for unsecured loans because the assessee produced confirmations, ledger accounts, income-tax returns, financial statements and bank statements showing identity, creditworthiness and genuineness, with receipts routed through banking channels and no rebuttal by the Revenue. It also accepted telescoping where the cash used for cheque-against-cash entries was linked to an already taxed on-money stream, so the related principal and interest additions did not survive. On disallowance of interest for diversion of borrowed funds, the Tribunal sustained only the reduced amount after finding no error in the appellate working of interest-free funds and advances.
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