The Appellate Tribunal held that there was no provision to disregard the loss declared by the assessee nor a provision by which the Department could ignore the sale price declared by the assessee and proceed to enhance the sale price without any material to show that the assessee had in fact realised a higher sale price. There was no expenditure which was incurred by the assessee and one could not proceed on the basis of a presumption that the profit forgone was expenditure incurred and that the expenditure incurred was for acquiring intangible assets like brand and goodwill. (AYs. 2012-13 to 2014-15)