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 allowed the appeal and deleted the penalty imposed under s. 271(1)(c) on the assessee, holding that the AO erred by attributing joint-account cash deposits solely to the assessee without verifying receipts by other joint-account holders or confining additions to the extent of income declared by the assessee or deposits attributable to him. The Tribunal found the AO failed to make requisite enquiries into family-member deposits and proceeded to levy penalty without proper basis. The Tribunal also noted procedural prejudice: notices were not received by the assessee due to communications sent to an incorrect email ID. On these grounds the penalty was held unjustified and set aside.
ITAT allowed the appeal and deleted the penalty imposed under s. 271(1)(c) on the assessee, holding that the AO erred by attributing joint-account cash deposits solely to the assessee without verifying receipts by other joint-account holders or confining additions to the extent of income declared by the assessee or deposits attributable to him. The Tribunal found the AO failed to make requisite enquiries into family-member deposits and proceeded to levy penalty without proper basis. The Tribunal also noted procedural prejudice: notices were not received by the assessee due to communications sent to an incorrect email ID. On these grounds the penalty was held unjustified and set aside.
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