Registration under s.12AB upheld; CIT(Exemptions) exceeded jurisdiction by deciding taxability instead of preliminary verification and registration di...
Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
The ITAT held that the assessing officer must compute tax liability on the addition under section 69A at the 30% rate prescribed by the pre-amended section 115BBE, rejecting application of the post-amendment 60% rate; the Tribunal followed the reasoning of its coordinate bench and applied precedent to direct reassessment consistent with the pre-amendment regime. The AO is directed to determine tax on the specified addition accordingly, with consequential adjustments as necessary. The additional ground invoked by the assessee is allowed and the matter is remitted for computation and assessment in accordance with this direction.
The ITAT held that the assessing officer must compute tax liability on the addition under section 69A at the 30% rate prescribed by the pre-amended section 115BBE, rejecting application of the post-amendment 60% rate; the Tribunal followed the reasoning of its coordinate bench and applied precedent to direct reassessment consistent with the pre-amendment regime. The AO is directed to determine tax on the specified addition accordingly, with consequential adjustments as necessary. The additional ground invoked by the assessee is allowed and the matter is remitted for computation and assessment in accordance with this direction.
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