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 allowed the petition, setting aside the impugned order dated 09.09.2024, and directed respondents to refund the contested amount with statutory interest at 6% per annum from the date the order of the First Authority became operative, on the ground that the refund was not made within 60 days of that order. The court rejected respondents' plea to attract the higher 9% rate, noting petitioners sought only 6% and that the Appellate Authority had quashed the original rejection dated 14.09.2020. The HC held the rejection to be unlawful and confirmed entitlement to the specified interest on the delayed refund.
The HC allowed the petition, setting aside the impugned order dated 09.09.2024, and directed respondents to refund the contested amount with statutory interest at 6% per annum from the date the order of the First Authority became operative, on the ground that the refund was not made within 60 days of that order. The court rejected respondents' plea to attract the higher 9% rate, noting petitioners sought only 6% and that the Appellate Authority had quashed the original rejection dated 14.09.2020. The HC held the rejection to be unlawful and confirmed entitlement to the specified interest on the delayed refund.
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