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 of the assessee, holding that income from the felling and sale of eucalyptus and wattle trees cultivated on agricultural land constituted agricultural income within the meaning of s.2(1A) of the Act. The Tribunal found that the assessee undertook basic and subsequent operations, processing and sale of the produce, and that the AO's field inspection, which recorded absence of standing produce, did not negate the existence of agricultural activities. Accordingly, the AO's disallowance and consequential addition to income from other sources were set aside and the CIT(A)'s confirmation of that disallowance was held unjustified; the assessee's ground was allowed.
ITAT allowed the appeal of the assessee, holding that income from the felling and sale of eucalyptus and wattle trees cultivated on agricultural land constituted agricultural income within the meaning of s.2(1A) of the Act. The Tribunal found that the assessee undertook basic and subsequent operations, processing and sale of the produce, and that the AO's field inspection, which recorded absence of standing produce, did not negate the existence of agricultural activities. Accordingly, the AO's disallowance and consequential addition to income from other sources were set aside and the CIT(A)'s confirmation of that disallowance was held unjustified; the assessee's ground was allowed.
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