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...
Rectification under section 254(2) is confined to a patent, obvious error apparent from the record and cannot be used to reargue debatable issues, reassess evidence, or reopen the merits of an earlier time-bar dismissal. The High Court held that complaints about the Tribunal's failure to summon further material, its treatment of the driver's affidavit on delay condonation, and alleged non-consideration of precedent involved adjudicatory choice rather than self-evident error, so no rectifiable mistake was shown. In the section 260A appeal, interference was unavailable absent perversity or a substantial question of law. The appeals were dismissed.
Rectification under section 254(2) is confined to a patent, obvious error apparent from the record and cannot be used to reargue debatable issues, reassess evidence, or reopen the merits of an earlier time-bar dismissal. The High Court held that complaints about the Tribunal's failure to summon further material, its treatment of the driver's affidavit on delay condonation, and alleged non-consideration of precedent involved adjudicatory choice rather than self-evident error, so no rectifiable mistake was shown. In the section 260A appeal, interference was unavailable absent perversity or a substantial question of law. The appeals were dismissed.
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