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...
The HC quashed the impugned assessment order dated 16.02.2024 and remitted the matter to the 2nd Respondent for fresh adjudication after observing that the Petitioner failed to respond to the SCN dated 30.12.2023 and subsequent notices. Consistent with precedent, remand is conditioned upon the Petitioner's additional pre-deposit of 15% of the disputed tax in cash from the Petitioner's Electronic Cash Register/Electronic Credit Ledger, over and above the 10% already deposited before the Appellate Authority, such that total pre-deposit equals 25%. The 15% cash deposit must be made within 30 days of receipt of this order. Petition disposed by way of remand.
The HC quashed the impugned assessment order dated 16.02.2024 and remitted the matter to the 2nd Respondent for fresh adjudication after observing that the Petitioner failed to respond to the SCN dated 30.12.2023 and subsequent notices. Consistent with precedent, remand is conditioned upon the Petitioner's additional pre-deposit of 15% of the disputed tax in cash from the Petitioner's Electronic Cash Register/Electronic Credit Ledger, over and above the 10% already deposited before the Appellate Authority, such that total pre-deposit equals 25%. The 15% cash deposit must be made within 30 days of receipt of this order. Petition disposed by way of remand.
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