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 ITAT upholds the CIT(A)'s deletion of the penalty under section 271(1)(c) imposed on the assessee for alleged furnishing of inaccurate particulars of income. The Tribunal accepts that the assessee, in liquidation, could not file a timely appeal against the assessment order and that the AO's disagreement with the assessee's bad-debt claim and its evidentiary shortcomings did not, per controlling authorities, automatically attract penalty. On that basis the Tribunal affirms that imposition of the penalty was unsustainable and dismisses the revenue's appeal, thereby restoring the CIT(A)'s order deleting the penalty.
The ITAT upholds the CIT(A)'s deletion of the penalty under section 271(1)(c) imposed on the assessee for alleged furnishing of inaccurate particulars of income. The Tribunal accepts that the assessee, in liquidation, could not file a timely appeal against the assessment order and that the AO's disagreement with the assessee's bad-debt claim and its evidentiary shortcomings did not, per controlling authorities, automatically attract penalty. On that basis the Tribunal affirms that imposition of the penalty was unsustainable and dismisses the revenue's appeal, thereby restoring the CIT(A)'s order deleting the penalty.
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