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ITAT set aside the DRP directions and restored the file to the DRP for fresh consideration, holding that the DRP's order was ambiguous, factually confused and failed to address the core dispute on characterization of charter hire receipts (royalty v. presumptive income under s.44BB). The Tribunal observed the DRP erroneously discussed DTAA applicability and reopening under s.147 despite this being a normal assessment under s.143(3). ITAT directed the DRP to re-examine all issues raised by the assessee, afford the assessee a hearing, and issue clear, speaking directions to the AO to enable adjudication on merits.
ITAT set aside the DRP directions and restored the file to the DRP for fresh consideration, holding that the DRP's order was ambiguous, factually confused and failed to address the core dispute on characterization of charter hire receipts (royalty v. presumptive income under s.44BB). The Tribunal observed the DRP erroneously discussed DTAA applicability and reopening under s.147 despite this being a normal assessment under s.143(3). ITAT directed the DRP to re-examine all issues raised by the assessee, afford the assessee a hearing, and issue clear, speaking directions to the AO to enable adjudication on merits.
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