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 affirmed the CIT(A)'s allowance of the assessee's claim for deduction under s.80IA(4) in respect of income from container freight stations, dismissing the revenue's appeals for AY 2018-19 and 2020-21. The Tribunal held that the AO's disallowance was untenable where no distinguishing facts for the year under consideration were recorded and the issue had been previously adjudicated in the assessee's favor by a coordinate bench. In view of the CBDT clarification on the scope of s.80IA(4) and the binding ratio in the assessee's earlier proceedings, the ITAT declined to interfere with the appellate authority's order and dismissed the revenue's appeals.
The ITAT affirmed the CIT(A)'s allowance of the assessee's claim for deduction under s.80IA(4) in respect of income from container freight stations, dismissing the revenue's appeals for AY 2018-19 and 2020-21. The Tribunal held that the AO's disallowance was untenable where no distinguishing facts for the year under consideration were recorded and the issue had been previously adjudicated in the assessee's favor by a coordinate bench. In view of the CBDT clarification on the scope of s.80IA(4) and the binding ratio in the assessee's earlier proceedings, the ITAT declined to interfere with the appellate authority's order and dismissed the revenue's appeals.
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