Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
Exemption under s.10(23C)(iiiad) upheld; appeal allowed, interest and dividends excluded from annual receipts, disallowance deleted, capital gains exe...
ITAT directed deletion of additions made by the AO that were founded solely on discrepancies between amounts in Form 26AS and the assessee's cash-basis books, concluding that entries in Form 26AS do not constitute taxable income where the assessee follows cash accounting and has furnished corroborative evidence. Specific additions relating to unidentified payers, a corporate payor, and East West Pipeline Ltd. were deleted; an invoice amount not received was also held non-taxable. A residual discrepancy of Rs.61,500 relating to Rosmerta HSRP Ventures Pvt. Ltd. was remitted to the AO for verification. The AO is directed to verify overall group receipts under the cash system, afford the assessee opportunity to be heard, and may invoke section 133(6) for fact-finding.
ITAT directed deletion of additions made by the AO that were founded solely on discrepancies between amounts in Form 26AS and the assessee's cash-basis books, concluding that entries in Form 26AS do not constitute taxable income where the assessee follows cash accounting and has furnished corroborative evidence. Specific additions relating to unidentified payers, a corporate payor, and East West Pipeline Ltd. were deleted; an invoice amount not received was also held non-taxable. A residual discrepancy of Rs.61,500 relating to Rosmerta HSRP Ventures Pvt. Ltd. was remitted to the AO for verification. The AO is directed to verify overall group receipts under the cash system, afford the assessee opportunity to be heard, and may invoke section 133(6) for fact-finding.
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