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 under s.69A, holding that undocumented loose paper found at a third party's residence could not sustain an unexplained income addition against the assessee. The Tribunal found the AO's reliance on unsubstantiated inference from initials and an audio recording insufficient: the seized paper was undated and thus presumptively related to the year of search (FY 2020-21/AY 2021-22), not the assessment year to which the additions were made; no cash or corroborative documents were seized from the assessee; no enquiries were pursued concerning running bills; and the audio had no nexus to the assessee. Accordingly, additions based on the seized entries were deleted and grounds 1-3 were allowed.
ITAT directed deletion of additions made under s.69A, holding that undocumented loose paper found at a third party's residence could not sustain an unexplained income addition against the assessee. The Tribunal found the AO's reliance on unsubstantiated inference from initials and an audio recording insufficient: the seized paper was undated and thus presumptively related to the year of search (FY 2020-21/AY 2021-22), not the assessment year to which the additions were made; no cash or corroborative documents were seized from the assessee; no enquiries were pursued concerning running bills; and the audio had no nexus to the assessee. Accordingly, additions based on the seized entries were deleted and grounds 1-3 were allowed.
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