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 holds that the approving authority's mechanical approval under section 153D does not preclude substantive consideration; on facts the assessee's revised return declaring 14-15% profit is accepted because group net profit computed from seized and books material is 1.47%, substantially below declared rates and prior-year margins, hence no further addition warranted and impugned additions are deleted, allowing the assessee's cross-objection and dismissing the revenue's appeal. The CIT(A)'s rejection of AO's unsupported agricultural income estimate is upheld on documentary proof (J-forms, khasra/khatauni). Unsecured loans are treated as genuine under section 68 on furnished confirmations, PANs and ITRs; related additions are deleted and revenue's grounds dismissed.
ITAT holds that the approving authority's mechanical approval under section 153D does not preclude substantive consideration; on facts the assessee's revised return declaring 14-15% profit is accepted because group net profit computed from seized and books material is 1.47%, substantially below declared rates and prior-year margins, hence no further addition warranted and impugned additions are deleted, allowing the assessee's cross-objection and dismissing the revenue's appeal. The CIT(A)'s rejection of AO's unsupported agricultural income estimate is upheld on documentary proof (J-forms, khasra/khatauni). Unsecured loans are treated as genuine under section 68 on furnished confirmations, PANs and ITRs; related additions are deleted and revenue's grounds dismissed.
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