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...
Reassessment was quashed because the recorded reasons suffered from fundamental defects: no proper approval in the prescribed form, absence of signature on sanction, and material factual errors in the basis for reopening. The assessing officer's later attempt to substitute fresh reasons was not permitted under section 147, and the alternative reasons still rested on suspicion, third-party information about the assessee's husband, and no independent tangible material showing escapement in the assessee's own case. The Tribunal held this amounted only to a reason to suspect, not a valid reason to believe. Cross-objections were also rejected as time-barred, since they were filed 27 days late without any condonation request.
Reassessment was quashed because the recorded reasons suffered from fundamental defects: no proper approval in the prescribed form, absence of signature on sanction, and material factual errors in the basis for reopening. The assessing officer's later attempt to substitute fresh reasons was not permitted under section 147, and the alternative reasons still rested on suspicion, third-party information about the assessee's husband, and no independent tangible material showing escapement in the assessee's own case. The Tribunal held this amounted only to a reason to suspect, not a valid reason to believe. Cross-objections were also rejected as time-barred, since they were filed 27 days late without any condonation request.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
