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 Petitioner was directed to pursue the alternate remedy under s.246A of the Income Tax Act before the Appellate Commissioner; concurrently, the HC ordered that recovery proceedings under the impugned order be kept in abeyance in view of pending Tax Case Appeals. The Petitioner was granted condonation of delay and permitted to file the statutory appeal within 30 days of receipt of the order; upon filing, the appeal will be kept in abeyance and all further recovery proceedings stayed pending disposal. The Petitioner is permitted to contend before the appellate forum whether the precedent from the Punjab & Haryana HC favourable to taxpayers applies to its facts.
The Petitioner was directed to pursue the alternate remedy under s.246A of the Income Tax Act before the Appellate Commissioner; concurrently, the HC ordered that recovery proceedings under the impugned order be kept in abeyance in view of pending Tax Case Appeals. The Petitioner was granted condonation of delay and permitted to file the statutory appeal within 30 days of receipt of the order; upon filing, the appeal will be kept in abeyance and all further recovery proceedings stayed pending disposal. The Petitioner is permitted to contend before the appellate forum whether the precedent from the Punjab & Haryana HC favourable to taxpayers applies to its facts.
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