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 sets aside the impugned order dated 8/9/2025 that blocked the petitioner's credit ledger account for failure to comply with the procedural mandate of Rule 86-A, noting the absence of contemporaneous reasons and insufficiency of the "reason to believe" standard as applied; the tribunal/authority is also directed to provide a post-decisional hearing which the petitioner is willing to avail. Relief is granted on condition that the petitioner furnishes a bank guarantee from a nationalised bank in the sum of Rs.6,50,00,000. The petition is disposed of accordingly, subject to compliance with the conditional direction and reservation of appropriate administrative follow-up.
The HC sets aside the impugned order dated 8/9/2025 that blocked the petitioner's credit ledger account for failure to comply with the procedural mandate of Rule 86-A, noting the absence of contemporaneous reasons and insufficiency of the "reason to believe" standard as applied; the tribunal/authority is also directed to provide a post-decisional hearing which the petitioner is willing to avail. Relief is granted on condition that the petitioner furnishes a bank guarantee from a nationalised bank in the sum of Rs.6,50,00,000. The petition is disposed of accordingly, subject to compliance with the conditional direction and reservation of appropriate administrative follow-up.
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