Reassessment under s.148A held valid; s.69 additions totaling Rs.7,00,000 deleted after acceptable contemporaneous explanations for property investmen...
Adjudication set aside; Rule 9 valuation based on internet engineer report quashed for Rule 3(4) non-compliance; Section 138B cross-examination requir...
The ITAT upheld that a unilateral APA, covering AYs 2016-17 to 2020-21 and rolled back to AYs 2012-13 to 2015-16, applies to AY 2013-14 for the issue of reimbursement of AMP expenses; accordingly, appeals of the assessee and revenue on that issue were dismissed. On alleged TDS defaults under s.195 and consequent disallowance u/s 40(a)(i) for payments to non-residents, the ITAT found material facts regarding the nature of services, cost-plus markup and the "make available" contention were not on record; the claims warranted re-verification. The ITAT set aside the AO's and CIT(A)'s orders and remitted the matter to the AO for fresh adjudication in accordance with law.
The ITAT upheld that a unilateral APA, covering AYs 2016-17 to 2020-21 and rolled back to AYs 2012-13 to 2015-16, applies to AY 2013-14 for the issue of reimbursement of AMP expenses; accordingly, appeals of the assessee and revenue on that issue were dismissed. On alleged TDS defaults under s.195 and consequent disallowance u/s 40(a)(i) for payments to non-residents, the ITAT found material facts regarding the nature of services, cost-plus markup and the "make available" contention were not on record; the claims warranted re-verification. The ITAT set aside the AO's and CIT(A)'s orders and remitted the matter to the AO for fresh adjudication in accordance with law.
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