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 set aside and quashed the respondent's assessment and demand notices, holding that the Principal Commissioner rightly limited proceedings to an Rs. 80 lakh property purchase and treated only Rs. 2,84,060 as assessable under s.69. The court accepted that the applicant had availed the Income Disclosure Scheme, 2016 and had declared and credited disclosed amounts to bank accounts, precluding the Revenue from reopening tax liability on those disclosures absent fraud or misrepresentation. Consequently the HC quashed the assessment framed under ss.147, 144 and 144B and the impugned order dated 14.11.2023, thereby nullifying consequential notices and restraining further assessment beyond the restricted scope determined by the appellate authority.
The HC set aside and quashed the respondent's assessment and demand notices, holding that the Principal Commissioner rightly limited proceedings to an Rs. 80 lakh property purchase and treated only Rs. 2,84,060 as assessable under s.69. The court accepted that the applicant had availed the Income Disclosure Scheme, 2016 and had declared and credited disclosed amounts to bank accounts, precluding the Revenue from reopening tax liability on those disclosures absent fraud or misrepresentation. Consequently the HC quashed the assessment framed under ss.147, 144 and 144B and the impugned order dated 14.11.2023, thereby nullifying consequential notices and restraining further assessment beyond the restricted scope determined by the appellate authority.
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