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 holds that DGIT (Investigation) possessed supervisory and administrative jurisdiction over the CIT(A)-11 and, notwithstanding a directive to refrain from adjudicating pending appeals, the CIT(A)-11 adjudicated numerous appeals after the specified date. The impugned orders passed by the CIT(A)-11 after 18.06.2018 are declared erroneous, illegal and without jurisdiction. The HC affirms the ITAT's orders setting aside those CIT(A)-11 determinations, upholds the ITAT's exercise of jurisdiction to set aside and transfer matters as appropriate, and dismisses the appeals challenging the ITAT's decisions, thereby denying the assessee relief on the contested rectification and transfer issues.
The HC holds that DGIT (Investigation) possessed supervisory and administrative jurisdiction over the CIT(A)-11 and, notwithstanding a directive to refrain from adjudicating pending appeals, the CIT(A)-11 adjudicated numerous appeals after the specified date. The impugned orders passed by the CIT(A)-11 after 18.06.2018 are declared erroneous, illegal and without jurisdiction. The HC affirms the ITAT's orders setting aside those CIT(A)-11 determinations, upholds the ITAT's exercise of jurisdiction to set aside and transfer matters as appropriate, and dismisses the appeals challenging the ITAT's decisions, thereby denying the assessee relief on the contested rectification and transfer issues.
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