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 observed that the rejection of the assessee's applications for registration u/s 12AA and approval u/s 80G, premised on non-registration under the RPT and questioned genuineness of activities, could not be sustained without affording an opportunity to cure curable defects. Noting that RPT registration was in the finalization stage, the Tribunal held that a liberal approach is warranted, declined to decide merits, and remitted the matter to the assessing authority with a direction to afford the assessee an adequate opportunity of hearing and to permit submission of clarifications and documents to establish registration status and genuineness before passing a fresh decision.
ITAT observed that the rejection of the assessee's applications for registration u/s 12AA and approval u/s 80G, premised on non-registration under the RPT and questioned genuineness of activities, could not be sustained without affording an opportunity to cure curable defects. Noting that RPT registration was in the finalization stage, the Tribunal held that a liberal approach is warranted, declined to decide merits, and remitted the matter to the assessing authority with a direction to afford the assessee an adequate opportunity of hearing and to permit submission of clarifications and documents to establish registration status and genuineness before passing a fresh decision.
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