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 held that a PCIT order under s.127 effected exclusive jurisdiction transfer to DCIT/ACIT, Central Circle-2, Madurai with effect from 09.12.2020; administrative delay in ITBA migration does not defer legal effect. Consequently, the ITO, Ward-4, Tirunelveli's notice issued u/s 143(2) on 29.06.2021 was without jurisdiction, invalid and liable to be quashed, rendering any resulting assessment order void ab initio. On merits, ITAT upheld the CIT(A)'s deletion of additions: an addition for alleged undisclosed business income based solely on survey notings was unsupported by corroborative evidence, and an addition u/s 68 read with s.115BBE was incorrect as amounts were opening balances, not credits in the year.
ITAT held that a PCIT order under s.127 effected exclusive jurisdiction transfer to DCIT/ACIT, Central Circle-2, Madurai with effect from 09.12.2020; administrative delay in ITBA migration does not defer legal effect. Consequently, the ITO, Ward-4, Tirunelveli's notice issued u/s 143(2) on 29.06.2021 was without jurisdiction, invalid and liable to be quashed, rendering any resulting assessment order void ab initio. On merits, ITAT upheld the CIT(A)'s deletion of additions: an addition for alleged undisclosed business income based solely on survey notings was unsupported by corroborative evidence, and an addition u/s 68 read with s.115BBE was incorrect as amounts were opening balances, not credits in the year.
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